69
January 2019 Edition V. “Crypto Winter Edition Demelza Kelso Hays Mark J. Valek Custody Solutions for Cryptocurrencies Securitization or Tokenization? Could a Bitcoin Standard work?

January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

  • Upload
    others

  • View
    0

  • Download
    0

Embed Size (px)

Citation preview

Page 1: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

January 2019 Edition V.

“Crypto Winter Edition”

Demelza Kelso Hays

Mark J. Valek

Custody Solutions for Cryptocurrencies

Securitization or Tokenization?

Could a Bitcoin Standard work?

Page 3: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Contents

Editorial ................................................................................................................................................................................. 4

In Case You Were Sleeping: Crypto Winter Edition ............................................................................................................ 6

The Crash and the Consequences ...................................................................................................................................... 7

Asset Class and Adoption ................................................................................................................................................. 11

M&As and Europe ............................................................................................................................................................. 14

Central Banks and Stablecoins ......................................................................................................................................... 15

ICO-Bust and Outlook ....................................................................................................................................................... 19

Crypto Concepts: Custody Solutions for Crypto Currencies .......................................................................................... 22

Not All Institutional Storage Solutions Are Made Equal ..................................................................................................... 23

Crypto Storage AG ............................................................................................................................................................ 24

Card Wallet ....................................................................................................................................................................... 27

Daenerys & Co. ................................................................................................................................................................ 28

Blockvault ......................................................................................................................................................................... 30

Swiss Crypto Vault AG ...................................................................................................................................................... 31

HSMs Matter and Outlook ................................................................................................................................................. 33

A Bitcoin Standard? Saifedean Ammous Musing with the Crypto Research Report ..................................................... 35

Bitcoin’s Stock-to-Flow Ratio is Lower Than Gold’s ........................................................................................................... 36

Taming Bitcoin’s Volatility?................................................................................................................................................ 37

Can a Deflationary Monetary System Work? ..................................................................................................................... 39

The Current Monetary System is Debt-Based ................................................................................................................... 39

A Free Market for Money .................................................................................................................................................. 42

Bitcoin: Two Paths to Monetization ................................................................................................................................... 43

Institutional Requirements for an Investible Crypto Index .............................................................................................. 45

Creating a Benchmark for a Premature Market ................................................................................................................. 46

The Creation of the LIMEYARD Cryptoasset Index (LYCAI) .............................................................................................. 47

Incrementum Investible Cryptoasset Index ........................................................................................................................ 48

Final Remarks ................................................................................................................................................................... 49

Equity Tokens ..................................................................................................................................................................... 50

Institutional Money-Steering Innovation ............................................................................................................................. 51

Define Token and Security ................................................................................................................................................ 52

Should I Tokenize or Securitize or Both? .......................................................................................................................... 53

Legal Challenges for Blockchain-Based Capital Markets ................................................................................................ 58

Capital Flows to the US ..................................................................................................................................................... 59

Classification of Tokens as Securities ............................................................................................................................... 60

Primary Market: Issuance of Security Tokens ................................................................................................................... 62

Secondary Markets: Trading in Security Tokens ............................................................................................................... 63

Final Remarks ................................................................................................................................................................... 64

Disclaimer:

This publication is for information purposes only and represents neither investment advice, nor an investment analysis or an invitation to buy or

sell financial instruments. Specifically, the document does not serve as a substitute for individual investment or other advice. The statements

contained in this publication are based on the knowledge as of the time of preparation and are subject to change at any time without further

notice. The authors have exercised the greatest possible care in the selection of the information sources employed, however, they do not

accept any responsibility (and neither does Incrementum AG) for the correctness, completeness, or timeliness of the information, respectively

the information sources made available, as well as any liabilities or damages, irrespective of their nature, that may result therefrom (including

consequential or indirect damages, loss of prospective profits or the accuracy of prepared forecasts).

Copyright: 2019 Incrementum AG. All rights reserved.

Page 4: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Editorial

Dear Reader,

The end of the year is always a good time to look back and contemplate what

lessons we can learn for the New Year. During 2018, the Crypto Research Report

covered regulation in the US and in Europe and provided insights on various

crypto concepts like smart contracts, hard forks, and consensus mechanisms. In

terms of market action, we offered a somewhat critical view. In the inaugural

edition of December 2017, we dedicated a chapter on ICOs, called “ICOs. Scams

and Big Hopes”. Obviously, we were quite critical towards the ICO-bonanza. 12

months later we feel very vindicated in our opinion, as many ICOs have failed. In

our March edition, we featured an article on technical analysis called “Is a Crypto

Winter About to Start?” The author, Florian Grummes, nailed it when he pointed

out that there was a good chance that we would see $4,500 to $5,200 by summer.

Figure 1: March Forecast of Bitcoin Downwards

In our October edition, we presented a valuation methodology based on our

quantitative network effect. It also suggested that Bitcoin, and several other coins

were still overvalued. However, on a critical note to a piece of content, we would

like to state the following: In Figure 9 of the June edition of the Crypto Research

Report, we plotted cryptocurrency consensus mechanisms according to their

degree of centralization and external trust anchor. However, recent research by the

International Organization for Standardization (ISO) provides a more elegant

method for classifying consensus or governance mechanisms. Simply put, a

public blockchain means anyone can read. A permissionless

blockchain means anyone can write. Cryptocurrencies such as Byteball Bytes

and XRP have a transparent ledger of transactions that can be viewed publicly;

however, validation or witnessing can only be done by authorized nodes. Privacy

Source: Midas Touch, Incrementum AG

Page 5: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

5

Twitter: @CryptoManagers

coins that have opaque blockchains, such as Monero and ZCash, fall in the

opposite category, private and permissionless.

Table 1: Concensus Mechanism Classification

Permissioned Permissionless

Public Ripple/IOTA/Byteball Bitcoin

Private Hyperledger Privacy coins

A formal definition of “blockchain” is also starting to convalesce in the academic

literature. A blockchain is a distributed ledger database that has a

consensus mechanism. Therefore, distributed ledger technologies (DLT) are

the broad category of peer-to-peer database structures and DLTs include

Hyperledger, Bitcoin’s blockchain, and IOTA’s directed acyclic graph.

Figure 2: October’s Forecast of Bitcoin Downwards

Source: Coinmetrics; Incrementum AG.

Winter is the perfect season of the year to cuddle up at home and do some research

on cryptocurrencies. This edition of the report covers institutional grade

storage solutions, security token offerings, a real cryptocurrency index

that considers liquidity and regulations, and an exclusive interview

with Saifedean Ammous. With this, we send you cordial season greetings and

hope you enjoy our January Edition of the Crypto Research Report.

Demelza Kelso Hays and Mark Valek

Incrementum AG

Page 6: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

In Case You Were

Sleeping:

Crypto Winter Edition

“The idea of having an alternative to traditional fiat money is attractive, especially today, when major

currencies’ savings value is in jeopardy and the trust they require to work is declining. Central banks are no longer focused on their duty to protect money’s value and have instead bowed to the pressure spendthrift governments have put on them to finance oversized

public debts.”

Princess Gisela von und zu Liechtenstein

Key Takeaways

Gross profit margins on mining Bitcoin and Ethereum have fallen to 30% and 15% respectively.

Never the less Bitcoin will not enter a “death spiral” as some critics have proposed. Enough

miners are incentivized to stay in the market as the difficulty falls.

The rumor that Goldman Sachs’ crypto trading desk was cancelled is “fake news.” Not only is

Goldman launching a trading desk, they are also working on a digital asset custody solution.

Due to the recent high volatility in the crypto markets demand for stable coins has increased.

Various interesting projects are being worked on right now.

Page 7: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

7

Twitter: @CryptoManagers

Crypto-winter is in full swing. In the background, the major

players are working on the infrastructure while the authorities

are clearing up the debris of the ICO hype.

About ten years after the publication of the famous white paper by Satoshi

Nakamoto, almost everything has been said about Bitcoin's anniversary. Therefore,

our greetings do not go to the mysterious inventor or inventors of the

cryptocurrency, but to Alicia Florrick. The likeable (and fictional) lawyer from the

CBS hit series "The Good Wife" had already dealt with a Bitcoin case in 2012. It

was probably the very first Bitcoin reference in a mainstream television show.

The scriptwriters deserve praise. Not only because they made Bitcoin an issue

when the cryptocurrency was worth just three dollars apiece. But also,

because they could explain this new innovation within a few minutes. The

viewers were not only entertained, but also well informed when Alicia's teenage

children taught her about Bitcoin step by step. Something that others have often

failed to replicate when it comes to Bitcoin.

When the Simpsons mentioned Bitcoin a year later, it was – of course – in the way

of a joke (S25E07). The protagonist in this case was Krusty the Clown. Lisa

Simpson asked Krusty if he was broke, and he answered: "Yeah, all it takes is some

bad luck at the ponies, worse luck in the bitcoin market, and heavy investment in a

high-end bookmark company." This rather depressive perspective fits in well with

Bitcoin's past anniversary year.

As far as prices were concerned, 2018 was virtually the opposite of

2017. After the euphoria came disillusionment. After the boom came the bust.

$20,000 was followed by $10,000. Then the $6,000 mark was held for a long

time. Until the end of November. Then it went rapidly down – triggered by a

dispute in the Bitcoin Cash Community. Bitcoin slipped into the $3,000 area. The

media published obituaries. Like so many times before. Explanations of what

Bitcoin actually is are no longer necessary. Bitcoin has actually arrived in the

mainstream. It was a long way. The colleagues from "Breaker Magazine" have

compiled a whole list of Bitcoin references in pop culture from the past ten years.

They ask, "What does Bitcoin in the mainstream actually mean?” Is it about the

price? Is it about using the cryptocurrency in the coffee house? Or is it about fame?

We also ask ourselves these questions.1

The Crash and the Consequences

Since Bitcoin was first mentioned in "The Good Wife", the price has risen by more

than 10,000 percent. The first ten years of the cryptocurrency are actually an

incredible success story.

1 https://breakermag.com/a-comprehensive-list-of-crypto-references-in-pop-culture/

Source: David M. Russel/CBS

Page 8: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

8

Twitter: @CryptoManagers

But all this does not seem to interest anyone after the depressing year 2018.

Bitcoin had to celebrate his birthday with a tear in his eye. Recently, there has even

been debate about a death spiral. Some argue that miners will simply stop

their activities if the price falls below the cost of production.

"Once Bitcoin’s price falls below its cost of mining, the incentive to mine will

deteriorate, thrusting bitcoin into a death spiral. That is, without the mining

activities supporting the ledger that maintains the records of who owns what

— bitcoin is, after all, a set of encrypted numbers that cannot establish the

ownership of anything — bitcoin will become worthless."2

Atulya Sarin

This view of things is not new. The same debate has been going on since 2011.

Today, the industry is much bigger, but the answer to the scaremongering remains

the same. As then, the prophets of Bitcoin's death overlook the nuances in the

game theory behind the cryptocurrency. Satoshi Nakamoto prepared the network

very well for a rapid drop in prices. After 2016 blocks, the difficulty is

adjusted. If the price drops and the number of miners shrinks, the software is

designed to make mining easier for the remaining miners. The argument of the

death spiral is based on the assumption that the price could fall so quickly that the

system does not adjust difficulty in time - and the miners give up. But there are

solutions for this problem. Andreas Antonopoulos explains:

"If the miners wait until the difficulty retargets and the difficulty becomes

less, then each miner who waits makes more profit because in the new scheme

they have a greater percentage of the mining power than they did before."3

In addition, one must consider: Mining costs are not the same everywhere, each

miner has his or her own calculations. Some might even be able to temporarily

mine at a loss. And if all else fails, there is still the option of a hard fork, which

would allow the immediate adjustment of the difficulty. That would be the last

resort.4

Of course, this does not mean that all miners did survive the fall in prices

unscathed. The situation is quite dramatic. Bitcoin miners are used to huge gross

profit margins of up to 50 percent. Since the fall in prices, the situation has become

tougher, as BitMEX has calculated. Currently, profit margins are only 30

percent for Bitcoin and 15 percent for Ethereum. There are also a number

of mining companies that have misjudged the situation and already went

bankrupt. The cleansing of the market during the price decline does not only apply

2 https://www.marketwatch.com/story/bitcoin-is-close-to-becoming-worthless-2018-12-03 3 https://www.marketwatch.com/story/why-bitcoin-by-design-wont-become-worthless-according-to-this-crypto-

heavyweight-2018-12-05?mod=newsviewer_click 4 https://www.theblockcrypto.com/2018/12/04/the-bitcoin-mining-death-spiral-debate-explained/

“The blockchain is a distributed

network that solves all the

problems that we have of

finance, but more broadly, it’s

like a philosophy. It’s a way of

life.”

Mike Cernovich

Page 9: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

9

Twitter: @CryptoManagers

to crypto projects, but also to the mining sector.5 The CIO of BlockTower Capital,

Ari Paul, explained on Episode 95 of Laura Shin’s Unchained podcast that mining

as an industry is not profitable because miners compete with each other in a zero-

sum game.6

And when it comes to Bitcoin as a currency, things look even grimmer. Around

Bitcoin’s 10th birthday in October, plenty of experts lampooned Bitcoin’s

irrelevance as a means of payment.

"In 2018, cryptocurrencies in general have sharply limited relevance, if any,

to the way that money is moved around the world. Bitcoin is an

undoubtedly valuable commodity and is by far the highest-profile

and most important of the cryptocurrencies, but it is not actually a

currency in any real sense. It is used for some payments, mostly peer-to-peer,

between parties for whom the anonymity of Bitcoin is important, or between

the remaining true believers in the global potential of the system."7

Samuel Murrant, GlobalData's payment analyst

But that's a very one-dimensional view of Bitcoin – and Murrant knows it too. He

follows up: "Bitcoin is far more like gold than it is like money – it is a store of

value, considered precious due to its rarity, and traded among investors to profit

from changes in its perceived value over time."

Bitcoin has therefore created its own asset class: crypto. The fact that a bubble

burst at the beginning of the year cannot be denied. Air is still escaping. In our very

first report in December 2017, we warned of the ICO boom and its consequences.

In the March issue of this year we wrote an article entitled "Is there a crypto winter

threatening us?” Currently, the northern hemisphere is not only in a

meteorological winter, but globally we are seeing the second deepest crypto-

winter after the bear market of 2014 and 2015. This adjustment may have

run its course, although that’s too early to call.

From an economic point of view, this is positive: after a bubble, only a

crash can lay the foundation for new, sustainable growth. Unfortunately,

however, crypto, which Morgan Stanley now also sees as an "institutional asset

class", is so young that we have little experience of how long such an adjustment

could take.8 We can only wait and see how the big players position themselves for

the next phase. And, as we have been documenting regularly for more than a year,

there is a hell of a lot going on.

5 https://blog.bitmex.com/the-price-crash-the-impact-on-miners/6 http://unchained.forbes.libsynpro.com/ari-paul-on-why-bitcoin-is-a-good-value-buy-today-ep957 https://www.globaldata.com/ten-years-bitcoin-now-no-relevance-payments-says-globaldata/8 https://www.coindesk.com/morgan-stanley-says-crypto-is-a-new-institutional-asset-class/

"To raise equity, an Initial Coin

Offering, or ICO, system was

developed. This uses the

blockchain technology to replace

the stock market, and effectively

decentralizes its function of

supplying capital to the

economy."

Princess Gisela von und zu

Liechtenstein

Page 10: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

10

Twitter: @CryptoManagers

The second sector, where Bitcoin and blockchain have undoubtedly

innovated, is payment traffic and the area of currencies in general. Not

necessarily because Bitcoin has asserted itself as a means of payment. We know

that didn't happen. The real breakthrough is mainstream acceptance of digital

currencies per se and "private" digital currencies in general. So much is happening

here that even the central banks can no longer just idly watch. In a digital world,

cryptocurrencies, and privately issued stablecoins in particular, offer an alternative

to the Euro, Dollar or Pound.

Figure 3: 2018’s Negative Return of 70% Requires Gain of 233%.

Source: Incrementum

Bitcoin has also significantly influenced a third sector: cybercrime.

Unfortunately, Bitcoin's second appearance on "The Good Wife" in 2013 was

already about a ransomware extortion. The good news: Supervisory authorities are

cracking down on fraud in crypto. From our point of view, this is very positive for

the sector. 2018 may have been depressing in terms of prices, but this leads to an

automatic market cleansing, and it gives the cops time to hunt scammers. The SEC

even punished celebrities for advertising scamcoins for the first time. More about

that later.

“Trust is established through

mass collaboration and clever

code rather than by powerful

intermediaries like governments

and banks.”

Don Tapscott,

author of The Digital Economy,

Wikinomics

Page 11: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

11

Twitter: @CryptoManagers

Asset Class and Adoption

As Michael Novogratz, one of the best-known crypto investors, puts it: "One thing

you learn in this process is that everything takes a little longer than you hoped it

would." We won't see the $10,000 mark again this year, the Bitcoin bull

recently said. His company, Galaxy Digital Holdings, has already posted more than

$150 million in losses this year. But Novogratz, one of Wall Street's best-known

Bitcoin supporters, won't give up.9 On the contrary: Novogratz, himself a former

Goldman Sachs partner, recently invested in BitGo Holdings – together with the

investment bank. Goldman and Galaxy Digital Ventures hope that the start-up will

provide a solution to the still unsolved problem of custodianship of cryptoassets.

US regulators require money managers to store assets in so-called "qualified

custodians". The traditional players in this sector have so far stayed away from the

crypto market for fear of hackers and the legal uncertainty that still prevails.10

Figure 4: Timeline of Famous Hacks.

Source: Incrementum

"If you were investing in any other asset class, you’re probably not worried about

the asset just disappearing – but this one, people still have that fear," said Mike

Belshe, BitGo's co-founder and CEO in an interview with Bloomberg. His company

has now collected around $70 million through fundraising. The Palo Alto-based

company was founded in 2013 and offers digital wallets that require multiple

signatures for transactions. Offline safes for Bitcoin and other currencies are also

9 https://www.bloomberg.com/news/articles/2018-10-15/novogratz-says-bitcoin-rally-likely-to-take-place-next-year 10 https://www.bloomberg.com/news/articles/2018-10-18/goldman-wades-deeper-in-crypto-betting-on-bitgo-with-

novogratz

Page 12: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

12

Twitter: @CryptoManagers

available. The company currently manages 75 different cryptoassets and

a total volume of around $2 billion dollars. But the entry of Novogratz and

Goldman could take BitGo to a whole new level.

Goldman is certainly one of the most courageous banks on Wall Street when it

comes to Bitcoin. "We believe that a custody offering is a logical precursor to

digital asset market making," said Goldman spokesman Michael DuVally. Reports

that Goldman has cancelled its plans for its own crypto trading desk in view of the

price drop have led the bank to deny this as "fake news". Allegedly Goldman is

also working on their own solution for Bitcoin custodianship. One thing is certain:

as long as these questions have not been clarified, the crypto market will

remain closed both to the "normal" retail investor and to almost all

institutional investors. In this issue we dedicate an entire chapter to safe

custody solutions that already exist or are going live soon.

Another important player who wants to compete against Goldman in this area is

Fidelity Investments. The company, which manages $7.2 trillion in

customer funds in its traditional business, established its own crypto

subsidiary in October. Under the name Fidelity Digital Asset Services,

customers will be able to trade Bitcoin on various stock exchanges at the best

prices. Cold storage, i.e. safe storage without an internet connection, could be part

of the package right from the start.11

"If you look at the existing market infrastructure, it’s heavily skewed toward

the needs of retail investors and early adopters of the space. The time is quite

good for this announcement. We’ve seen a real acceleration of demand over

the last couple months."

Tom Jessop of Fidelity

Fidelity has been experimenting with Bitcoin since 2014, and they have even

mined hundreds of Bitcoins. In the Fidelity canteen you can now pay with Bitcoin.

"The question is, how do we stay ahead of the competition? How do we innovate

and bring new products onto the platform?" asks Jessop.

It is by no means the case that all institutional investors are merely sitting on the

sidelines and waiting. In fact, institutional investors may have replaced high net

worth individuals as the largest buyers of cryptocurrencies. These trades usually

take place directly between investors and large miners or people with large Bitcoin

fortunes. According to current estimates, this over-the-counter (OTC) market

sees a daily volume of $250 million to $30 billion dollars.12 For

comparison: According to "coinmarketcap.com", cryptoassets worth around $15

11 http://fortune.com/2018/10/15/fidelity-launches-company-help-hedge-funds-big-investors-trade-crypto/ 12 https://www.bloomberg.com/news/articles/2018-10-01/institutional-investors-are-using-back-door-for-crypto-

purchases

“The blockchain does one thing:

It replaces third-party trust with

mathematical proof that

something happened.”

Adam Draper

Page 13: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

13

Twitter: @CryptoManagers

billion are traded daily on the exchanges. Some of the stock exchanges listed there

are however not considered to be very reputable and their figures should be viewed

with skepticism. At the University of Liechtenstein, a comprehensive analysis is

currently being carried out on this subject, which deals with the actual market

depth of the asset class. The results of the study will certainly be a topic in one of

our next issues.

There is no doubt that the OTC market has also suffered from the price decline.

Nevertheless, growth can be observed here, says Jeremy Allair, CEO of Circle

Internet Financial in Boston: "We’ve seen triple-digit growth enrolling in

our OTC business. That’s a big growth area." This growth is likely to

continue as long as institutional investors enter the market. Because they often

need more coins than are offered on the exchanges. Or they are afraid of moving

the price too far by buying or selling big amounts. That's why they look for trading

partners.

None of this is hidden from the big Wall Street banks. We've heard about Goldman

and Fidelity. But it looks like Fear of Loss (FOL) is quickly transitioning

to Fear of Missing Out (FOMO). Morgan Stanley, Citigroup and Bank of

America Merrill Lynch are also reportedly working on their own Bitcoin products

to meet customer demand.13 Russia's Gazprombank is also venturing into the

market via a subsidiary in Switzerland.14

And then there are the big US universities that manage their income and donations

in endowments. 96 percent of university money managers still say they

don't want to touch the crypto market. In a recent interview with Mark

Yusko, we discussed university investments in cryptocurrencies because some of

the big names like Harvard, Stanford and MIT are already in business.15 The same

goes for Yale. The elite school recently invested in the Paradigm Fund, which was

launched by former employees of Coinbase, Sequoia Capital and the Pantera

Capital crypto fund. A total of around $400 million is invested in this fund.

However, it is not known how much of this comes from Yale's $30-billion-dollar

purse. But the step is significant, because Yale's money is managed by David

Swensen.16 Swensen is considered a pioneer among institutional investors and has

managed some of the best performing college endowments over the past decades.

He focuses on long time horizons and often on markets with low liquidity assets.

Many other universities try to imitate him. Under Swensen, Yale has seen a return

of almost 12 percent annually - over the past 20 years. In total, more than $500

billion dollars are invested in the funds of US colleges.17

13 https://bitcoinexchangeguide.com/breaking-bank-of-americas-merrill-lynch-to-launch-bitcoin-trading-product-to-

rival-goldman-sachs-and-morgan-stanley/ 14 https://gazprombank.ch/news/gazprombank-switzerland-ltd-prepare 15 https://www.theinformation.com/articles/harvard-stanford-mit-endowments-invest-in-crypto-funds 16: https://www.incrementum.li/journal/advisory-board-discussion-q4-2018-blockchain-technology-the-biggest-

wealth-creation-opportunity-of-our-lifetime-feat-special-guest-mark-yusko/ 17 https://www.bloomberg.com/news/articles/2018-10-05/yale-is-said-to-invest-in-crypto-fund-that-raised-400-million

“This is the missing piece for

infrastructure — it’s a

treacherous environment today.

Hedge funds need it, family

offices need it, they can’t

participate in digital currency

until they have a place to store it

that’s regulated […] This is early

stages in an industry that’s

volatile right now. We’re in a

down cycle in terms of where

we’re going, but the institutions

see an opportunity. It’s going to

progress quickly.”

Mike Belshe,

co-founder and CEO of BitGo

Page 14: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

14

Twitter: @CryptoManagers

Two important players have recently underlined their interest in the crypto market

but have adjusted their schedule to the new pricing conditions. Bakkt, the crypto

platform of Intercontinental Exchange (ICE), has postponed the launch of its own

Bitcoin futures until the end of January. "As is often true with product launches,

there are new processes, risks and mitigates to test and re-test, and in the case of

crypto, a new asset class to which these resources are being applied", said Bakkt

CEO Kelly Loeffler. The partnerships between ICE, mother of the New York Stock

Exchange, and Starbucks as well as Microsoft are still up to date - but there are no

new details.18 Nasdaq also intends to stick to its plan to enter the market with

futures contracts. Starting date is the first quarter of 2019, but talks are still

underway with the US regulatory authority CFTC. Nothing is set in stone.19

M&As and Europe

Another way to enter crypto is to become active in business yourself or to buy up

other companies. We have already mentioned several times that the market crash

of the past months can be good for Bitcoin - because dubious projects become

unprofitable as a result and perhaps even disappear. At the same time, the sector is

being consolidated and the financially strong companies are going on a shopping

spree. By October, the number of mergers and acquisitions (M&As) in the

crypto sector had already risen by more than 200 percent - compared to

the previous year. At least 30 deals are still open.20

The crypto industry is global and so far, appropriately, without a real financial

center. One of the biggest and most interesting deals, therefore, did not take place

in the USA, but in Europe. The Belgian investment company NXMH has

just bought the Bitstamp stock exchange - and paid cash for it. The

purchase price was not stated. Two years ago, Bitstamp, the largest cryptocurrency

exchange in the European Union, was valued at around $60 million. It can be

assumed that the valuation for the sale was significantly higher after the 2017

boom. Bitstamp has more than three million registered users and a daily

trading volume of $100 million dollars. For the two founders, Nejc Kodrič

and Damian Merlak, the deal was definitely successful. They founded Bitstamp in

Slovenia in August 2011 - in a garage. Their starting capital: A server, a few laptops

and a thousand euros in cash. Today, Bitstamp is registered in Luxembourg. It is

supposed to stay that way after the deal.21

18 https://www.theblockcrypto.com/2018/11/20/bakkt-has-pushed-back-its-bitcoin-futures-launch-to-2019-but-phase-

two-is-still-on-track/ 19 https://www.bloomberg.com/news/articles/2018-11-27/nasdaq-is-said-to-pursue-bitcoin-futures-despite-plunging-

prices 20 https://www.cnbc.com/2018/10/18/crypto-deal-makers-see-opportunity-in-bitcoins-price-slump.html 21 https://www.businessinsider.com/r-european-investment-firm-buys-digital-exchange-bitstamp-in-all-cash-deal-

2018-10?IR=T

“Everything will be tokenized

and connected by a blockchain

one day.”

Fred Ehrsam

Page 15: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

15

Twitter: @CryptoManagers

Two more anecdotes from Europe, this time from the German-speaking area,

which is very close to us. We know from past reports that Switzerland is actively

trying to attract Blockchain and Bitcoin companies. As we reported in detail in our

October issue, the government of Liechtenstein is planning its own law, which is

already being praised by many as exemplary. But even the giant Germany is by no

means inactive. The hipster capital Berlin has a lively crypto scene. Now there is

an advance from the party of chancellor Angela Merkel. The CDU wants

to make Germany the number one ICO country and a "blockchain

financial centre".22

Austria has another way of doing things. In Austria, ICOs are supposed to be

carried out with legal certainty soon. A working group is to present results by the

end of the year - then there will be a new law. But a lot is already happening on a

small scale. The Graz-based company Coinfinity and the privately-owned

Austrian state printing company have developed a solution for

physical, offline storage of Bitcoin private keys. This is called “Chainlock” -

and is the solution to the custodian problem, so to speak, but more for private

individuals than for institutional investors.23

And the Viennese law firm Stadler & Völkel has succeeded in getting a

capital market prospectus for a Security Token Offering (STO)

approved by the supervisory authority for the first time.24 An STO can be

understood as a further development of the ICO. Like share owners, holders of

security tokens also have securitized rights and are not solely dependent on the

price development of a purchased token - as was the case with ICOs. In return, the

security tokens are subject to the same rules as other securities. For this reason,

Austria requires approval from the Financial Market Authority (FMA) before such

a token can be sold. The security token of Hydrominer, whose prospectus has just

been approved, is expected to be available to investors in February 2019.25

Central Banks and Stablecoins

After just learning a new abbreviation (STO) we now present another

one: CBDC. Central Bank Digital Currency. The subject is getting hotter

every day. Although to this day it's not even clear what we're actually talking about.

The media likes to pretend that the central banks experimenting with digital

money are developing their own "cryptocurrencies" like Bitcoin. But it's not that

simple. For them, the blockchain is a vehicle to create a digital equivalent for cash.

22 http://www.faz.net/aktuell/finanzen/digital-bezahlen/cdu-vorschlag-deutschland-soll-mekka-fuer-kryptogeld-

werden-15887209.html?printPagedArticle=- sync:ßÇÈâÈâ<font color="#ffff00">-= 23 https://www.trendingtopics.at/card-wallet-coinfinity-und-staatsdruckerei-bringen-neue-speicherloesung-fuer-

bitcoin/ 24 One of the partners of the law firm, Oliver Völkel, is member of the Advisory Boards of the Crypto Research

Report. 25 https://diepresse.com/home/wirtschaft/recht/5541879/Depot-in-der-Hosentasche_FMA-approved-

BlockchainEmission

“The interesting thing about

blockchain is that it has made it

possible for humanity to reach

consensus about a piece of data

without having any authority to

dictate it.”

Jaan Tallinn

Page 16: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

16

Twitter: @CryptoManagers

Nouriel Roubini, the notorious Bitcoin hater, is firmly convinced that the CBDC of

the future will kill Bitcoin. Because no one would accept anarchy-money if they

could have state money, he reasons. However, Roubini overlooks the fact that

Bitcoin has something that digital central bank currencies can never have: its

deflationary character as discussed in depth in the interview with Saifedean

Ammous contained in this edition of the report.26

It is extremely unlikely for a central bank to ever issue a currency that

tends to appreciate. In the event of over-indebtedness, the expansion of the

money supply is often used as a form of concealed state financing. What can no

longer be completely ruled out today is the "denationalization of money" as

demanded and predicted by Friedrich August Hayek. He envisioned that

commercial banks will come into the market as money producers. That is still

possible. As far as private money is concerned, we are at the very beginning, but

the most important steps have been taken.

Christine Lagarde, the influential head of the International Monetary Fund (IMF),

has become aware of the issue. Central banks around the world need to be more

open to new technologies, she said recently in Singapore. "I think we should

consider issuing a digital currency. There must be a role for the state to provide the

digital economy with money.”27 She speaks of a "counterweight" for private

currencies and thus shows that even the high priests of money now consider the

existence of Bitcoin to be a given. Lagarde, like Hayek, also wants to involve the

banks. But them printing their own money is not part of the plan. Lagarde sees

CBDC primarily as a substitute for cash: "A digital currency could bring advantages

as a last resort for payments. And it could drive competition forward because it

offers an efficient alternative at a low price - just like its grandfather, the old,

reliable paper money." But the complete anonymity of cash would then be

gone.

26 https://www.project-syndicate.org/commentary/central-banks-take-over-digital-payments-no-cryptocurrencies-by-

nouriel-roubini-2018-11 27 http://www.faz.net/aktuell/wirtschaft/diginomics/iwf-chefin-fordert-digitale-waehrungen-15889788.html

“Alternatively, not to act in the

face of current developments and

completely leave the payment

market to private agents, will

ultimately leave the general

public entirely dependent on

private payment solutions, which

may make it more difficult for

the Riksbank to promote a safe

and efficient payment system.”

Riksbank

Page 17: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

17

Twitter: @CryptoManagers

Figure 5: Tether USD Price and Growing Capitalization

Source: Coinmarketcap, Incrementum AG

Instead, Madame Lagarde proposes to record transactions and pass on the

details to the state only in case of suspicion. A delicate idea - but not

completely crazy, at least in constitutional countries where there is a separation

between the state and the central bank. However, Lagarde’s own experts from the

IMF are quite skeptical about the subject. A recent IMF paper on the subject states:

"All in all, it is still too early to assess the benefits of CBDC. Central banks

should take into account the specific circumstances in their respective

countries, pay cautious attention to risks and the benefits of other solutions. It

needs further analysis and studies of technical feasibility and costs."

It should be noted at this point that central banks are notoriously slow when it

comes to technical innovations. The plans for CBDC are by no means mature. One

thing is certain: we are not talking about digital money as we already know it. An

account balance is ultimately a claim to the bank. CBDCs must be currencies with

no counterparty risk - as with Bitcoin or gold. Even if the true motivation of

central banks and the IMF is the preservation of the money monopoly,

the efforts to obtain their own digital money ultimately indirectly

legitimize private alternatives such as Bitcoin conceptually.

It should come as no surprise to anyone that Sweden is the country where plans for

a CBDC are the most advanced. Sweden is regarded as the test tube of a cashless

society and is now reaching the limits of what is feasible. There have long been

protests by citizens against the abolition of cash, which has been pushed mainly by

banks. This is one of the reasons why the central bank launched the E-Krona

project and is currently investigating the various technical possibilities for

introducing an electronic Krona. The Riksbank, the Swedish central bank, has now

“A Blockchain fulfills the ideal

conditions for digitizing money,

assets and intellectual property.”

Princess Gisela von und zu

Liechtenstein

May 2018 Jul 2018 Sep 2018 Nov 2018

0

50M

100M

150M

200M

0.98

1

1.02

1.04

1.06

1.08

0

20M

40M

60M

80M

Market Cap (USD) Daily Volume (USD) Tether Price (USD)

Page 18: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

18

Twitter: @CryptoManagers

called on the government to create the necessary legal framework for a possible

introduction of an E-Krona. "If the marginalisation of cash continues, a digital

krona, an e‐krona, could ensure that the general public still has access to a state-

guaranteed means of payment", the Riksbank said.28

Figure 6: Stablecoins Categorized by Funding in Dollars

Source: Incrementum AG

2019 will see the rise and expansion of private stablecoins. Joining

Tether is also the Gemini Dollar, TrueUSD and Paxos. And of course, USDCoin,

which is backed by no one other than Circle, in which Goldman Sachs is also

invested. USDCoin is now even used and offered by the Bitcoin giant

Coinbase.2930 Currently there are more than 50 such stablecoins. Some of them

are not even tied to an existing national currency - but most of them are. During

falling Bitcoin prices, investors can save their digital money in a USD stablecoin

and wait until the market calms down. Of course, the controversies surrounding

the original stablecoin Tether are not over. Even the US authorities are now

investigating accusations that the backers of Tether and the Bitfinex stock

exchange manipulated the Bitcoin price.31

28 http://fortune.com/2018/10/26/sweden-riksbank-e-krona/29 https://www.bloomberg.com/news/articles/2018-10-29/stable-coin-backed-by-circle-coinbase-draws-most-early-

demand 30 https://www.bloomberg.com/news/articles/2018-10-23/crypto-exchange-coinbase-to-list-stable-coin-backed-by-

circle?srnd=cryptocurrencies 31 https://www.bloomberg.com/news/articles/2018-11-20/bitcoin-rigging-criminal-probe-is-said-to-focus-on-tie-to-

tether

“It is a good alternative to

central bank-issued money and

through competition could

eventually enforce more

monetary policy discipline in the

current system.”

Princess Gisela von und zu

Liechtenstein

Algorithmic

174,000,000

49.6%

Off-Chain Asset Backed

144,000,000

41%

Crypto-Collateralized

33,000,000

9.4%

Page 19: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

19

Twitter: @CryptoManagers

Figure 7: Stablecoins in Comparison

Source: Coinmarketcap, Incrementum AG

ICO-Bust and Outlook

The SEC has dozens of investigations into crypto matters under way.32

Two providers of ICOs (Airfox and Paragon Coin) had to pay fines of $250,000

each and compensate investors. They conducted their ICOs after the SEC issued an

explicit warning last summer that ICOs were illegal sales of securities.33 The

penalties imposed by the SEC on two celebrities who had advertised dubious

crypto currencies are likely to be much more effective. The boxer Floyd

Mayweather and the hip-hop star DJ Khaled accepted fines of $300,000 and

$100,000 dollars, respectively, as part of a settlement. The celebrities also had to

relinquish the proceeds from their promotional activities - amounting to a further

$300,000 and $50,000 respectively. According to the SEC, they had advertised

ICOs on social media without disclosing that they were being paid.

Both celebrities had advertised Centra, a project that has been in the SEC's sights

for quite some time. "Investors should be sceptical about investment advice posted

on social media platforms and not make decisions based on recommendations

from celebrities", warned Steven Peikin of the SEC. "Social media influencers are

often paid promoters.”34

While we consider it positive that the authorities have intervened here, it must be

said that it is a drop in the ocean. Investors should be extremely careful with any

form of information they obtain from the crypto-media and crypto-influencer

environment. Three independent studies have shown that the media, so-

called rating agencies, and individuals on social media and on YouTube

are highly corrupt. The "Breaker" magazine wrote to 22 different crypto media

32 http://fortune.com/2018/11/02/sec-ico-report-cryptocurrency-scams/ 33 http://fortune.com/2018/11/16/sec-airfox/ 34 https://diepresse.com/home/wirtschaft/5538851/KryptogeldWerbung_High penalties for Boxer Mayweather and

DJ Khaled

“It’s surprising just how easy it is

without any tech skill to commit

cybercrimes like ransomware.”

Rick McElroy,

Carbon Black security strategist

Tether $2.6B

TrueUSD $71.7M

DAI $54.5M

Bridgecoin $25.1M

BitUSD $11.9M

AAA Reserve $3M

Digix Gold $1.9M

Nubits $1.7M

Hellogold $1.3M

NUSD $1.1M

Page 20: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

20

Twitter: @CryptoManagers

companies from a fake address of an alleged Russian PR man. The result: more

than half of the websites would have taken money for articles without

marking them as "ads" or "sponsored". Some were even willing to simply

adopt ready-made PR texts and pass them off as their own. The smallest websites

took less than $300. The largest more than $3000. In any case, this study explains

why there are so many miserably written texts on the Internet about relatively

obscure coins. Advertising is subtle. Among the websites that take money for

reports are some of the best-known names in the cryptosector. But to be fair:

Around 10 of the websites contacted immediately rejected the offer.35

But news sites are just the tip of the iceberg. The covert advertising campaigns are

often managed by so-called ICO agencies, which have price lists for various

channels at hand. These agencies do not only take care of the marketing of a coin

on the relevant websites, but also provide comments and traffic in the Telegram

groups and other social networks. Many people who discuss cryptocoins or

ICOs on YouTube are also paid for their service. Research by Breaker,

Techcrunch and Reuters paints a picture of a deeply corrupt industry at the heart

of which is the hunt for money by ICOs.3637

If the drop in prices and the SEC's crackdown leads to this swamp being drained,

then this should be welcomed. This is part of the development of the sector

towards more professionalism. As far as mainstream acceptance is concerned, we

no longer need to worry. Years after Bitcoin's first appearance on "The Good Wife",

a feature film with Kurt Russel is soon to come. The title is simply "Crypto".38

And shortly before this report went to press, this news came in: Electronics giant

Samsung is supposedly working on a cryptowallet for their smartphones. If there is

any truth to this, it would be another big step into the mainstream. And a

confirmation of the old thesis: While prices are falling, true innovations are

taking place.39

35 https://breakermag.com/we-asked-crypto-news-outlets-if-theyd-take-money-to-cover-a-project-more-than-half-

said-yes/ 36 https://www.reuters.com/article/us-crypto-currencies-promoters-specialre/special-report-little-known-to-many-

investors-cryptocurrency-reviews-are-for-sale-idUSKCN1NW17S 37 https://techcrunch.com/2018/09/18/inside-the-pay-for-post-ico-industry/ 38 https://www.imdb.com/title/tt8563452/ 39 https://www.sammobile.com/2018/12/11/exclusive-samsung-bitcoin-app-cold-wallet-cryptocurrencies/

“For Mises, gold’s industrial role

is an impediment to performing

its monetary role, an

impediment with which he is

happy to contend compared to

the alternative of money whose

supply is controlled by

governments.”

Saifedean Ammous

Page 22: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

**

Crypto Concepts:

Custody Solutions for

Crypto Currencies

“The next level for the crypto community is for additional institutions to enter the space. They will only do so if there is a super secure way of storing the assets

or the private key.”

Philipp Vonmoos, CEO of Swiss Crypto Vault AG

Key Takeaways

At no point should a crypto custody solution provider have access to a client’s unencrypted private key.

The industry standard may very well become Hardware Security Modules (HSMs) for the creation of

private keys.

Reputation and experience should be considered when evaluating a crypto custody solution for your

organization.

Consider that outsourcing your private key storage is similar to outsourcing your gold storage. In case

of an emergency, will you be able to access your cryptocurrency if someone else is the gatekeeper?

Authored by Joseph Annuzzi Jr.

Joseph Annuzzi Jr is the founder and CEO of a stealth cryptocurrency decentralized

exchange and the sole inventor of a novel cryptocurrency secret key protection

algorithm designed for consumers. He is a software architect and entrepreneur from

Silicon Valley and an author of a series of computer science text books published by

Pearson Education, Inc. He is also the owner of cryptocustodysolutions.io a resource

for crypto custody solutions. Photo: Joseph Annuzzi

Page 23: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

23

Twitter: @CryptoManagers

In this article, we explore solutions for institutional cryptocurrency

custody. Cryptocurrency custody solutions are needed because improper

handling and storage of cryptocurrencies can result in loss or even theft. Self-

managed cryptocurrency accounts are not insured against loss or theft, and law

enforcement may have difficulty in recovering stolen cryptocurrency such as

Bitcoin depending on the different ways thieves attempt to mask their efforts.

From a regulatory point of view, professional custody solutions can also be

compulsory. As is the case with investment funds. Thus, there is an increased

demand for professional solutions.

Not All Institutional Storage Solutions Are Made Equal

Let’s begin with a brief overview of some of the components required

to use cryptocurrency. One such component is a cryptographic key pair in the

form of a public key and private key. The public key is used to derive a public

cryptocurrency address that may be made available to the public. A cryptocurrency

address is very similar to an email address, meaning, anyone with knowledge of

the address can send information to that address, in the form of a balance of coins

or tokens. A cryptocurrency address has a record of its balance and is able to

receive and send an amount of cryptocurrency, provided the owner of the

cryptocurrency address has access to its associated private key. The private key

must always remain private and is much like a password for a particular

cryptocurrency address. Only the owner of a cryptocurrency address should have

access to the private key. Revealing the private key to an unauthorized party puts a

cryptocurrency address at risk for theft of its balance. Further, to spend any

balance associated with a particular cryptocurrency address, access to the private

key of that address is required to authorize the transaction. One wouldn’t want to

give an unauthorized party access to their email password, so in the same respect,

one would not want to give an unauthorized party access to their cryptocurrency

private key. The cryptocurrency address or the balance associated with a

cryptocurrency address is not the asset that needs protection. A user’s private key

associated with a cryptocurrency address is the asset that needs protection.

In the last issue of the Crypto Research Report, we explored this topic and titled

the entire issue ("Handy Theft Edition"). The private key requires extreme care

and consideration with its storage and security and failure to maintain the utmost

of care may result in loss or theft of cryptocurrency. Anyone who has been around

the cryptocurrency space for some time has probably seen news related to theft of

cryptocurrency. Theft of cryptocurrency has been a focus of cyber criminals

because once stolen, it is impossible to reverse a transaction. The only

way to recover any funds would be to gain access to any private key associated with

any cryptocurrency address that has taken custody of the stolen funds. Good luck

locating extremely sophisticated cyber criminals in this day and age.

Theft is not limited to criminals hacking into computer systems of an organization.

Theft could also originate from within the organization if one or more of the wrong

personnel are put in charge of the safekeeping of the private keys associated with

“As the crypto-asset class

seasons and institutional

demand builds, there are a

plethora of opportunities for

traditional firms to engage in the

eco-system. These include the

provision of custodial and asset

management services as well as

traditional brokerage functions

like market-making.”

CNBC

Page 24: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

24

Twitter: @CryptoManagers

any cryptocurrency address holdings. Let’s consider how institutions are

organized, for example, a corporation or other similarly organized entity. Being

that an institution may be made up of more than one individual, comprising

personnel that makes up a board of directors, executive management, and other

such employees, how should a company decide who should have the rights to

access and secure the private key associated with a cryptocurrency address?

Should it be the chairman? The board? An executive, such as the CEO or the CFO?

A particular employee such as a software developer? What about a combination of

one or more of the preceding options? An organization might ultimately decide

that a combination of personnel comprised of a board member, an executive, and a

software developer is required to transact with any cryptocurrency holdings.

With the complexities associated with storing and securing cryptocurrency, we

should be able to see that there is an opportunity for businesses to provide

cryptocurrency custody solutions for those lacking the sophistication or resources

required for securing private keys for cryptocurrency addresses that are associated

with large holdings.

Via our Twitter Channel @cryptomanagers, we invited institutional custody

solutions to provide us with some information about their products. The following

five companies which offer custodian services of cryptocurrencies reached out to

us. In exclusive interviews with the security officers, we gained knowledge of how

these different firms attempt to solve the custody problem for investors. Our

research results lead us to the conclusion that not all storage solutions are made

equal. Many thanks to all contributing companies for their helpful cooperation.

The results presented here are based on the information provided by the providers

and are not guaranteed.

Crypto Storage AG

The first crypto custody solution that we investigated was Crypto Storage AG.40

Crypto Storage AG is a subsidiary company of Crypto Finance AG which was

founded in 2017 and is based in Zug, Switzerland. Crypto Storage AG offers

services for storing blockchain based assets securely through a compelling

infrastructure solution. We had the pleasure of speaking with the CEO, Stijn

Vander Straeten, and the Technical Sales Engineer and Implementation Project

Manager, Maria Sommerhalder. According to the company’s material, they have

over 40 internal and 13 external professionals involved with creation and

implementation of the solution.

The infrastructure of Crypto Storage AG is made up of a transaction user interface

that communicates with a backend server infrastructure that specializes in

bookkeeping and relaying of messages between the Hardware Security Modules

(HSMs) and the Hardware Approval Terminals (ATs). An HSM is a computer with

40 See “Storage,” Crypto Finance, 2018.

“There are a lot of investors

where custodianship was the

final barrier. Over the next year,

the market will come to

recognize that custodianship is a

solved problem. This will unlock

a big wave of capital.”

Kyle Samani,

Multicoin Capital hedge fund

manager

“Blockchain Technology Could

Save Banks $12 Billion Per Year.”

Mohsin Jameel

Page 25: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

25

Twitter: @CryptoManagers

cryptographic processing capabilities that operates within a tamper-resistant

hardware device that is capable of performing encryption and decryption, key

generation, and digital signature creation and verification. Some HSM

manufacturers allow for customizing the processing capabilities through

programmable extensions made possible with software development kits or by

special request.

The backend server infrastructure and the HSMs are distributed across

Switzerland in a georedundant fashion, and one of the locations used to be a

military bunker located in the Swiss Alps. Georedundancy provides strong

assurances that if one location goes offline there is another location available as a

backup. The ATs are installed at the client’s facility and are linked

cryptographically with the backend servers and HSMs through encrypted

communication. The company behind the HSMs and the ATs is called Securosys,

which is based in Zürich, Switzerland. The company involved with the operational

security aspects and backend software development is AdNovum, which is also

based in Zürich, Switzerland. These companies assisted in the development and

implementation of Crypto Storage AG’s solution.

What is unique about the Crypto Storage AG solution is the combination of HSMs

and ATs that are cryptographically paired. This allows for both hot and cold

storage capabilities for the client where the private keys are generated on the HSM

and never leave the device, thus, being the cold storage aspect. Crypto Storage AG

is unable to access the client’s private keys stored on the HSM due to its secure

tamper-proof construction. In addition, the cryptographically paired ATs provide

hot-wallet-like capabilities where the client may initiate withdrawal

transactions out of cold storage while being able to rely on a secure

device. Crypto Storage AG refers to this as “deep cold storage allowing for the

flexibility and speed of a hot wallet.”

Further, the client is able to design a custom approval framework where the client

can mirror their own operational processes for approving crypto transactions. The

approval framework allows for the design of rules which are then stored with the

“The New York State Limited

Purpose Trust charter, which

now enables Coinbase Custody to

act as a Qualified Custodian for

crypto assets, builds on our

unparalleled success as a crypto

custodian while holding the

company to the same exacting

fiduciary standards and

oversight of other, mature

financial institutions operating

in New York.”

Asiff Hirji,

Coinbase COO and president

Approval Terminal and Hardware Security Module Increases Security. Source: Crypto Storage AG

Page 26: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

26

Twitter: @CryptoManagers

private key inside the HSM. For example, an m-of-n approver scheme might be

configured for initiating any transaction, where one or more groups of approvers

are required. Time delays may also be configured to ensure that any withdrawal

transaction follows the appropriate governance procedure suitable for the client.

The ATs have the same security standards as the HSMs and the ATs require a

personalized smart card and pin code per approver to initiate any withdrawal

transaction. This solution is an extremely powerful yet highly secure means of

storing and transacting with crypto.

Crypto Storage AG supports 59 out of the top 100 cryptocurrencies by

market capitalization and new cryptocurrencies are added regularly.

Target clients are banks, asset custodians, family offices, brokers, insurance

companies, pension funds, exchanges, and foundations. As for insurance, the

technical infrastructure is covered which may include some client

assets but not all. How much of one’s assets may be insurable is definitely worth

investigating when exploring Crypto Storage AG as a potential custody

infrastructure provider.

Overall, Crypto Storage AG has a very compelling solution worth exploring for any

institution or private individual that desires extremely secure storage with near

immediate withdrawal capabilities and a highly configurable governance process if

desired.

“As to storing coins safely, I’d say

a hardware wallet, however a lot

of care is required in avoiding

compromised hardware. Using

multiple hardware wallets from

multiple vendors in a multisig

configuration would probably be

the safest at this point.”

Mark Karpelès,

former chief executive of Mt.Gox.

Page 27: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

27

Twitter: @CryptoManagers

Card Wallet by Coinfinity.

Source: Coinfinity GmbH

Figure 8: System Architecture of Crypto Storage AG.

Source: Crypto Storage AG

Card Wallet

Card Wallet is another company that we reviewed, which is a co-

production between Coinfinity and the Austrian State Printing

House. Coinfinity is a Bitcoin broker based in Austria that offers

services to both businesses and consumers. Coinfinity also offers

consumers the ability to purchase Bitcoin at retail outlets

throughout Austria at nearly more than 4,000 locations and is

also known for installing the first Bitcoin ATM in Austria.

In addition to retail locations, Coinfinity also provides services that

allow merchants to get paid in Bitcoin. The Austrian State Printing

House is known for their services in printing identity documents in

a highly secure facility and controlled fashion. Together, their

services are used for operating Card Wallet.

Managing Director of Coinfinity, Max Tertinegg explained in an exclusive

interview that Card Wallet is a credit-card-sized tamper-proof card that

allows customers to store Bitcoin in an offline manner, similar to how

one would store Bitcoin using a paper wallet, that is, writing down the

private key on a piece of paper. The difference is that Card Wallet is a

polycarbonate plastic card and a Bitcoin private key is laser-etched directly onto

the card and then covered and sealed with a tamper-proof sticker. The private key

is generated with what Card Wallet defines as Secure Entropy Technology (SET).

Page 28: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

28

Twitter: @CryptoManagers

According to Max, SET leverages three random number generators for generating

the entropy for deriving a Bitcoin private key printed on the card. Entropy is a way

to generate an unpredictable output of information that is nearly impossible to

reproduce. The random number generators are made up of a hardware device

provided by the Austrian State Printing House, a software solution provided by the

Austrian State Printing House, and a human-

derived random number generator performed by the

personnel of Card Wallet by rolling dice and then

documenting the results to produce the random

number. When these three generated random

numbers are combined, they are used as inputs for

generating a Bitcoin private key that is then laser-

etched onto a physical card.

The printing of cards is performed in a secure room

of the Austrian State Printing House and, according

to Max, is protected by approximately seven or eight

different physical firewalls, so one could imagine

how secure the facility may be. No copy of any

private key is stored on any permanent storage

means, and, assuming the facility maintains its

security guarantees, in theory, the personnel at the

facility will never gain access to the private keys.

The card is reasonably priced at €59 and currently

supports Bitcoin. In the future, Ether along with

other cryptocurrencies will be supported. Card

Wallet is very similar to a pre-paid gift card and

seems most appropriate for insignificant amounts of

cryptocurrency, maybe for gifting a family member

or friend. Given the counterfeiting possibility of card

storage solutions, the party who receives this as a

gift should be told to only purchase new Card

Wallets directly from the manufacturer.

For the institutional or wealthy investor looking to

securely store hundreds of thousands, or millions, a

different custody option may be more appropriate.

In view of the possibility of forgery, Card Wallets

should only be purchased directly from the

manufacturer.

Daenerys & Co.

Daenerys & Co. is another crypto custody solution that comes from the Silver

Bullion Group. Silver Bullion Group was founded in 2009 by Gregor Gregersen

and is based in Singapore. Silver Bullion Group offers secure storage facilities for

precious metals, provides insurance, as well as liquidity services. Since 2009,

Silver Bullion Group has done over $400 million in sales. As Silver Bullion Group

Attack Vectors of Card Storage Solutions

1) Since the private keys exist on a computer system in

temporary memory for a brief moment in time before it is

laser-etched onto a card, a bad actor within the facility or

who compromised the facility infrastructure could

potentially gain access to one or more private keys. This

attack scenario is highly unlikely and would require the

coordination of many different parties to execute.

2) During the shipment of a card, a postal facility could

potentially intercept and swap a counterfeit card in place

of a genuine card as it is making its way to a customer.

This type of attack would require the coordination of

many actors across many different facilities, but it is not

impossible. Credit cards passing through postal facilities

on their way to unsuspecting customers have been known

to go missing while in transit. Registered shipping

significantly reduces the risk. Registered shipping

significantly reduces the risk.

3) Counterfeit cards listed for sale on an online marketplace,

such as eBay or Amazon, could accidentally be purchased.

A counterfeit card would mean the unsuspecting

customer is purchasing a deposit address under the

control of a criminal or a private key that has been

intentionally compromised so any deposits of Bitcoin

could be stolen by the criminal. Counterfeiting is not

impossible, as we have seen occurrences of counterfeit

consumer hardware wallets purchased at online

marketplaces, such as eBay and Amazon.

Page 29: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

29

Twitter: @CryptoManagers

Secure vault at the Daenerys facility.

Source: Daenery’s & Co.

Encrypted polycarbonate card of Daenerys & Co.

Source: Daenery’s & Co.

has done with safeguarding precious metals, Daenerys came from a need to solve

custodial and compliance issues as they pertain to digital assets. Gregor Gregersen

and Clint Mark Gono are positioning Daenerys to be a leader in the space with a

one-of-a-kind business and security protocol called the Gregersen-Gono Physical

Crypto Storage (GGPCS) standard.41 GGPCS is currently being used at Silver

Bullion Group’s vaulting company called The Safe House.

The process begins in a secure vault on computers that have

no Internet connection. These computers generate a Bitcoin

private key within the temporary memory of the computer, then

encrypt this private key with a first encryption key, and then encrypt

it once again with a second encryption key. Each of these encrypted

private keys is then laser-etched, in the form of a QR code, onto its

own polycarbonate plastic card, a primary card, and a recovery card.

Once the encryption process is finished, the private key is then wiped

from the computers’ temporary memory and is not stored anywhere

in the permanent storage of the device. The cards are then analyzed to

ensure the etching process performed as expected and that the QR code is

readable. The polycarbonate plastic is a material that is capable of surviving long

periods of time, although the material is not fireproof but supposedly

readable even if up to 30 % of the card become damaged. This is why it is

useful to have a primary card and a recovery card. If the primary card suffers any

sort of damage, the recovery card stored at a different physical location could be

used to recover any assets associated with that Bitcoin private key. Once the

etching process is complete, the card is then placed in a lockbox that resembles a

gold bar, and that lockbox is then stored in the facility in a manner similar to how

gold bars are secured.

Once the client has access to the deposit address associated with a particular

private key, the client is then able to initiate a deposit to that address. On the other

hand, withdrawals from this address require a multistep process to ensure the

withdrawal request is coming from the actual client initiating such a withdrawal.

Prior to a withdrawal, the client is required to configure Authorization Mandate

rules. These rules might reflect the client’s governance structure within their own

organization, where one or more authorized representatives, such as the CEO, the

CFO, and/or the compliance officer, are all required to approve such a withdrawal,

or possibly two of those three. Daenerys uses a live video conference to

authenticate the representative initiating the withdrawal, and any withdrawal may

only be made to a preapproved address.

Insuring one’s cryptocurrency assets is probably a great idea when someone else

maintains custody. Daenerys also offers an optional insurance policy

where an individual card is insurable up to $5 million. The insurance

41 See “Crypto Currency Physical Storage,” Gregor Gregersen and Clint Mark Gono, Little Bit, September 21, 2018.

Page 30: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

30

Twitter: @CryptoManagers

Blockvault focuses on Know-Your-Customer and

Anti-Money Laundering.

Source: Blockvault

provider has a Standard & Poor’s A+ rating, is based in London, and is something

worth looking into.

Blockvault

Another crypto custody solution investigated was Blockvault, which is powered by

Goldmoney Inc. We had the pleasure of speaking with Josh Crumb, co-founder

and director of Goldmoney, and Will Felsky, director of operations of Blockvault.

Goldmoney is a company that provides a way for institutions to invest in precious

metals. The company was also founded in 1999 and is a public company listed

on the Toronto Stock Exchange (XAUMF). Their current customers rely on

Goldmoney to secure $2 billion worth of assets. Goldmoney is also a debt-

free company with more than $100 million at its disposal.

Being that Goldmoney is in the precious metal’s storage business, they have access

to precious metal storage facilities around the world. Goldmoney saw an

opportunity to provide similar custody solutions for institutional clients in the

crypto space. They are leveraging their network of vault providers around the

world for Blockvault.

Blockvault offers its clients an offline private key storage of crypto. The private

keys are created by Blockvault, although the method of private key generation was

not disclosed during the interview. Regardless, client’s cryptoassets may be

covered under an insurance policy. The company’s auditor is KPMG, and they are

used to confirm and verify that the assets under its management are in fact in its

respective vault. KPMG is also the auditor for Goldmoney where they perform

IASC audits for gold bar custody confirmation. The Blockvault insurance they are

offering is made up of a collection of many of the major insurance companies.

Blockvault also mentioned that their vault providers, auditors, and insurance

partners are all publicly traded businesses. They are currently working

with vault providers in Canada, United States, United Kingdom,

Switzerland, Dubai, Singapore, and Hong Kong.

Blockvault described the high-level process of how their offering

works. It begins with know-your-customer (KYC) and anti-money-

laundering (AML) checks during the client onboarding process. Once

through the onboarding process, the client is provided with a trade

receipt of a list of addresses that they are able to deposit their crypto

funds to. Blockvault’s target clients are regulated or registered

financial institutions, banks, broker-dealers, registered funds,

cryptocurrency miners, and other similar businesses that can pass bank

level KYC/AML tests. The target customer is more than likely the

institution looking to safeguard $50 million or more in crypto, although

they would be willing to accept clients starting with $1 million. They

recommend that each address store approximately $50,000 worth of crypto, so if

depositing $1 million of crypto, those assets would be safeguarded across 20

different crypto addresses that have a corresponding key pair. Every deposit is

issued a trade receipt, and the governance model for how to deposit and withdraw

“A lot of people are unaware in

this new gold rush, people are

using cloud wallets and not

securing their money.”

Rick McElroy

Page 31: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

31

Twitter: @CryptoManagers

is customizable by the client, and that is something that is usually agreed-upon

through the contractual relationship with Blockvault. As for the maximum amount

of cryptocurrency insurable, they prefer to have those conversations directly with

the client. Further, withdrawals and trading of cryptocurrency assets are able to be

performed within one business day to an address of the clients choosing.

Assets that Blockvault supports safeguarding in their vaults include Bitcoin,

Bitcoin Cash, Ether, XRP, Litecoin, as well as all ERC20 tokens. Coming soon, they

will be supporting XLM. Blockvault also mentioned the potential for financial

institutions to white label the Blockvault service and offer it to their own clients.

Overall Blockvault seems to be in a great position and has a long history and track

record of safeguarding precious metals for its clients. Any company looking into

their solution should inquire about the private key generation and storage methods

employed and should also ask about their insurance policy.

Swiss Crypto Vault AG

Swiss Crypto Vault AG (SCV) is branded as a hyper-secure crypto storage solution

for institutional investors and high-net-worth individuals (HNWI) and is a joint

venture between Bitcoin Suisse AG and Swiss Gold Safe AG. For this interview, we

had the pleasure of speaking with Philipp Vonmoos, CEO of SCV.

If you are from the cryptocurrency space, you may have heard of Bitcoin Suisse,

who is known for its cryptocurrency-related financial services and storage

solutions for institutional and private clients. Established in 2013, Bitcoin Suisse

has helped facilitate and raise nearly ₣1 billion for initial coin offerings (ICOs) or

token generation events (TGEs) for some of the most well-known cryptocurrency

projects. If you are from the precious metals space, you may have heard of Swiss

Gold Safe AG, which is known for its precious metals and valuables storage

services. Established in 2006, Swiss Gold Safe has helped secure precious metals

and valuables for institutions and HNWI. SCV was formed under the laws of

Switzerland in 2017 and is based in Zug. The partnership between the two

organizations to form SCV was to combine their knowledge of cryptocurrency

handling and physical security and storage.

“Theft of cryptocurrencies

through hacking of exchanges

and trading platforms soared to

$927 million in the first nine

months of the year, up nearly

250 percent from the level seen

in 2017.”

CipherTrace,

US Cyber Security Firm

Page 32: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

32

Twitter: @CryptoManagers

Attack Vectors of Private Key Generation Without

Hardware Security Modules

1) As Daenerys does not use a Hardware Security Module

(HSM), there is a small window when the private key

remains within the temporary memory of the computer

that generates the private key. Being that the computer

has no Internet access, it’s impossible for hackers outside

the facility to penetrate their system, but it might be

possible for an insider, such as someone who has physical

access to the device that generates the private keys, to

compromise the device in some way. Considering how

secure the facility must be to store the amount of precious

metals Daenerys is safeguarding, executing this attack is

highly unlikely.

2) Another attack vector could be during a withdrawal

process, where internal personnel swap out a whitelisted

client address for their own.

Implementing the key creation process on an HSM would ensure

that the private key never has the ability to leave the device and

whitelisted addresses could also be preconfigured on the HSM.

Therefore, both attack vectors could be ameliorated if

implemented.

Figure 9: Withdrawal Process of Swiss Crypto Vault.

Source: Swiss Crypto Vault AG.

SCV’s solution provides clients with a deposit address

that is associated with a private key that was

generated on an HSM so the private key never

leaves the device. The client is able to deposit their

cryptocurrency assets as needed into the deposit address.

The private keys are redundantly distributed, after being

encrypted, ensuring that if one facility were to suffer a

catastrophic event there is a backup to your private keys.

The governance model is highly customizable by the

client, allowing for multi-signature transactions and role

designations of requester, controller, and approver. The

requester, using the web portal, is able to initiate

withdrawals. One or more controllers are able to cancel a

withdrawal request and two or more approvers are able

to approve a withdrawal request. An optional time delay

may also be defined, and withdrawals are only allowed to

be delivered to preapproved addresses. Another

configuration the client is able to make is the selection of

a handling partner. To prevent Swiss Crypto Vault from

having complete authority over the withdrawal process in

case their personnel or computer systems were to ever

become compromised, a handling partner is a

company different from Swiss Crypto Vault, that

provides the client with the additional benefit

that the authorization of 2 separate

organizations with different business operations,

personnel, and computer infrastructure are

required to authorize the client’s withdrawal request. Requiring 2

Page 33: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

33

Twitter: @CryptoManagers

organizations to authorize a withdrawal request is in addition to the clients own

configurable withdrawal approval process. Currently, the only handling partner is

Bitcoin Suisse, with the promise that other handling partners will be available for

clients to utilize in the future. This architecture is similar to a multi-signature

transaction, in that more than one party is required to authorize a withdrawal. In

other words, both Swiss Crypto Vault and the chosen handling partner (currently

only Bitcoin Suisse) must both agree to authorize a withdrawal request otherwise a

withdrawal request will be denied. This is a worthwhile safety feature which

reduces the odds of both organizations being compromised when a client makes a

withdrawal request.

PriceWaterhouseCoopers reviewed the storage solution, oversaw the private key

generation, and will also compare the amount of stored crypto assets to the

balances registered on the associated blockchain. Zuhlke Engineering reviewed the

private key generation code. They don’t yet offer insurance, but this is

something that they said they are looking into. As for their clients, they are

currently serving those from Europe, USA, Asia, and the Middle East. As for the

typical client deposit amount, SCV makes sense for those starting around

₣500,000, up to triple digit millions. A SCV client does not require any physical

hardware installed on their end, although they may co-sign a transaction with the

private key of their own Trezor or Ledger hardware wallet under their control.

They may also leverage multi-factor authentication for accessing the web portal.

Many types of cryptocurrencies are supported as of today, such as Bitcoin, Bitcoin

Cash, Bitcoin Gold, Ether, Litecoin, and all ERC20 and ERC223 tokens. Others will

be added on an ongoing basis.

Swiss Crypto Vault appears to be a highly redundant, highly secure, well thought-

out implementation and process that is also easy to use and configure by the client.

SCV is backed by a track record of experience and expertise in both cryptocurrency

and precious metals. The solution is suitable for both institutions and HNWIs, and

definitely a crypto custody solution worth investigating.

HSMs Matter and Outlook

In this article, we covered a few options for crypto custody solutions. Two solutions

ensure that a private key never leaves an HSM, two others generate the private key

in temporary storage where it remains for a brief moment. The final solution

desired to maintain confidentiality and secrecy of their private key generation

process. For those where the private key is not generated on a HSM, an insurance

policy could make up for any potential

vulnerabilities assuming the policy covers

theft and is bullet-proof. As for

technological innovation, speed, ease of

use, customization of governance,

physical security, and digital security, the

most well-rounded solutions appear to be

Swiss Crypto Vault AG and Crypto

Storage AG. Of those two, Swiss Crypto

“The New York State Limited

Purpose Trust charter, which

now enables Coinbase Custody to

act as a Qualified Custodian for

crypto assets, builds on our

unparalleled success as a crypto

custodian while holding the

company to the same exacting

fiduciary standards and

oversight of other, mature

financial institutions operating

in New York.”

Asiff Hirji,

Coinbase COO and president

Source: Scott Adams, Dilbert

Page 34: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

34

Twitter: @CryptoManagers

Vault AG has the longest track record and most experience. Crypto Storage AG

appears to be the most innovative solution. If your organization requires insured

options, Daenerys & Co. and Blockvault may be right for your organization. Both

are capable and in positions for the physical storage of large sums of

cryptocurrency. These evaluations are not meant to be recommendations of one

company over the other, as they each have their own use case. We should stress the

importance of doing your own due diligence when investigating the solution that is

right for your organization.

If you have any questions or comments, are looking for a solution for your

organization, or if you have your own solution that you are interested in sharing,

please head over to this website for participating in a brief survey and be entered

for a chance to win a Ledger Nano S sent directly from the manufacturer. Joseph

can also be reached at joseph (at) cryptocustodysolutions.io.

Disclaimer: Coinfinity and Silver Bullion are associated with In Gold We Trust and

the Crypto Research Report. None of the information you read in this article

should be taken as investment advice, nor do the writers of the Crypto Research

Report endorse any project that may be mentioned or linked to in this article.

Please do your own due diligence before taking any action related to content within

this article.

Page 35: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

A Bitcoin Standard?

Saifedean Ammous

Musing with the Crypto

Research Report

“Sound money is money that gains in value slightly over time, meaning that holding onto it is likely to offer an

increase in purchasing power”

Saifedean Ammous

Key Takeaways

One reason gold has been used as a store of value and medium of account is because of its low

annual supply growth. The optimal money would have zero supply growth.

In a free market for money, money would appreciate in value every year. Therefore, banks

would no longer pay interest on deposits. Instead, depositors would choose between a deposit

contract, a mutuum contract, or a private equity investment.

A debt-based monetary system must be inflationary because interest payments must be made.

As investors gradually purchase cryptocurrencies and pay off debt in the fiat system, the fiat

money supply will contract over time.

Page 36: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

36

Twitter: @CryptoManagers

We want to Thank Saifedean Ammous for having an exclusive

conference call with Demelza Hays and Mark Valek from

Incrementum. Saifedean Ammous is a Professor of Economics at the American

University in Lebanon, and he is the author of the bestseller The Bitcoin Standard.

Bitcoin’s Stock-to-Flow Ratio catching up to Gold’s

A starting point for Saif’s analysis of different monies is the stock-to-flow ratio.

Readers of our sister report – the “In Gold we Trust” Report are well aware of this

concept, as we have discussed it at length. Most people fail to understand why gold

has been used as a store of value for thousands of years. It is true that Gold is

scarce. However, it is definitely not the scarcest metal at all. Rather its above-

ground quantity has the most constant quantity of any rare commodity available.

The quantity of a good can be expressed in the stock-to-flow ratio. A high stock-to-

flow ratio means its quantity is not inflated very much. An ideal unit of account for

measuring value obviously needs low fluctuation of the ‘yard stick’. The master of

the British Mint and inventor of the gold standard, Sir Isaac Newton, said,

“Gentlemen, in applied mathematics, you must describe your unit.”

Even though gold has a very high stock-to-flow ratio, Bitcoin will soon

have a higher one. Its capped supply is one reason Saifedean Ammous

claims that Bitcoin is even better than gold.

In the figure below, Bitcoin has a stock-to-flow ratio of around 71 currently, but by

2020, because of the halving, the ratio will be going up to 119.

Figure 10: Bitcoin versus Gold Stock to Flow

Source: Incrementum

“For Mises, gold’s industrial role

is an impediment to performing

its monetary role, but an

impediment with which he is

happy to contend compared to

the alternative of money whose

supply is controlled by

governments.”

Saifedean Ammous

Source: Saifedean

Ammous

Page 37: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

37

Twitter: @CryptoManagers

Taming Bitcoin’s Volatility?

In The Journal of Structured Finance, Saif wrote a paper, “Can Bitcoin’s Volatility

Be Tamed”, about how the price of gold is affected by the demand from the

jewellery market and industry. When people sell gold excessively, the price of gold

drops. However, demand from jewelry makers and industrial fabricators absorbs

the price drop, which creates a lower bound for the price of gold and has a

moderating effect on the volatility of gold’s price.

In Paul Krugman’s article on why he is a crypto skeptic, he explained that Bitcoin is

not “tethered” to the real world like gold.42 Since there is no real-world

market that has demand for Bitcoin, the price of Bitcoin has no lower

bound, and therefore, Bitcoin can never ascend to the role of money.

However, Saif answers Krugman’s critique with a quote from Theory of Money

and Credit by Ludwig von Mises,

“The significance of adherence to a metallic-money system lies in the freedom

of the value of money from State influence that such a system guarantees.

Beyond doubt, considerable disadvantages are involved in the fact that not

only fluctuations in the ratio of the supply of money and the demand for it,

but also fluctuations in the conditions of production of the metal and

variations in the industrial demand for it, exert an influence on the

determination of the value of money.”43

As Saif explains, fluctuations in the demand from industry cause gold’s value to

fluctuate and prevent it from being a purely monetary asset that reflects monetary

demand only. He says that gold is not money because of its industrial activity.

Industrial activity is secondary in the determination of the value of gold. For Mises,

a money that has only a monetary demand will be a superior form of money

because the value of money will be based purely on time preference.

According to Saif, in a situation where Bitcoin becomes the only money in the

world, hypothetically speaking, then the demand for Bitcoin is just the demand for

cash balances. In other words, Bitcoin demand is a reflection of time

preferences.

Mark Valek, author of The Crypto Research Report and fund manager at

Incrementum, compares Saif’s idea with the “reservation demand with gold”. The

volatility of gold, due to this reservation demand, will probably always

be lower than Bitcoin as long as Bitcoin is only a store of value and only

potentially has monetary demand. However, in the future, if hypothetically a

majority of people adopt Bitcoin as unit of account, the volatility would be lower

than gold because Bitcoin would be the denominator of goods and services. In fact,

42 See “Transaction Costs and Tethers: Why I’m a Crypto Skeptic,” Paul Krugman, The New York Times, July 31,

2018.

43 See “The Theory of Money and Credit”, Ludwig von Mises

“A However, loose monetary

practices and overly

bureaucratic regulation of the

financial industry have caused

people to look for alternatives. A

traditional one for savers is gold,

but it is unsuitable for payments.

Now, many see an opportunity

for cryptocurrencies to meet this

need.

Princess Gisela von und zu

Liechtenstein

Page 38: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

38

Twitter: @CryptoManagers

if one starts using Bitcoin to measure goods and services the volatility would go to

zero, like during a gold standard.

Saif explains, “That is the idea of the stock-to-flow because, with gold, and

especially silver, yearly mining production does not significantly impact total

above ground supply compared to other metals. You want your money to be

purely your money.”

Mark compares the predetermined stock-to-flow ratio of Bitcoin with other rule-

based monetary policies, such as Milton Friedman’s automated k-percent rule44

and John Taylor’s Taylor Rule, that attempt to stabilize the purchasing power of

money over time. On the other hand, these attempts do not achieve long-term

sustainability because of political tension explained by Gordon Tullock and the

Public Choice literature on economics.

However, Saif does not believe that the k-percent rule and Bitcoin’s algorithm are

equivalent. “The key thing for me is that the value of money should be

determined by the market for money, which is the supply and demand

for cash balances.” The supply and demand for money are what determines the

price and the interest rate for money. It is very different from the rule-based

monetary policies because they want to calculate the right price, and then

they want the market to adjust.

While discussing the topic of Bitcoin with Larry White, he argued that gold has an

advantage over Bitcoin because its supply is elastic in the long run. Gold supply

increases by 1–2 % every year and inflation compounds. Within a 40 to 50 years,

the supply of gold will double. However, Saif couldn’t disagree more. According to

him, what makes gold a good money is the fact that it has the least

supply growth. Larry White is a supporter of fractional reserve banking on top of

a gold system because he holds that a fully backed gold standard would have a

shortage of money. Therefore, for Larry White, the reason gold became an

international money is because of the small 1–2 % in inflation every year. In

contrast, Saif says, “Gold wins out because the demand for money is always a

demand for a money that can be inflated the least. The demand for money

is always growing and the value of non-inflationary money always grows in the

long run. If we follow Larry’s argument, then we have to ask why did silver or

copper not become money instead of gold since they have supplies which are more

elastic to demand?”

44 See A Monetary History of the United States, 1867–1960.

“The virtues of the blockchain is

that it would be that it’s peer-to-

peer settlement – no centralized

settlement, no manipulation…

And most importantly, there’s

nothing to capture. It’s consensus

based. It’s stateless.”

Patrick M. Byrne

Page 39: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

39

Twitter: @CryptoManagers

Can a Deflationary Monetary System Work?

Mark Valek gets right to the point and asks, “Does the monetary system need

inflation at all?” Some gold proponents would argue that the monetary system

needs some monetary inflation to keep up with population growth. Saif claims the

following: “From a mathematical point as well as from the perspective of a Bitcoin

maximalist, I think the argument against inflation is quite strong as outlined by

Philipp Bagus’ book on deflation45: the hardest form of money is one with

constant money supply and zero elasticity.”

Demelza Hays, author of The Crypto Research Report and fund manager at

Incrementum, mentioned her 2017 Forbes article based on the work of Professor

Dr. Antal Fekete. She posited the question to Saif, “For me, it looks like we want to

have a currency with a high stock-to-flow ratio, but if we take to the logical

conclusion, why do we need money that has any flow at all?”

“We don’t need any flow! But we also don’t know any other economic

good that is more reliable at limiting flow other than Bitcoin, which has a

small annual inflation rate still. The government will make more fiat

money flow, the miners of gold will make more gold flow, the miners of

silver will make more silver flow. If you could find a way to make a

money that doesn’t have any flow, then go for it! That is what Bitcoin will

be doing in about 100 years from now.”

Saifedean Ammous

The Current Monetary System is Debt-Based

Mark Valek holds that central banks follow inflationary monetary policies and

governments support inflation when the monetary system is debt-based. “If we

have debt as the basis of our money, that requires an ever-increasing money

supply. Otherwise, I don’t know where the interest for the debt should

come from. Do you agree with that?”

“Yes, I definitely agree on that,” answers Saif. “I go even farther than most

Austrian economists. In a free market for banking, depositors would not

earn any interest on their deposits because the money would be

appreciating in value, which is the real return. Essentially, lending money

to the bank enables depositors to save on the cost of securely storage money. The

second kind of money would be the direct equity and that is the model

of Islamic banking, which is also the model of traditional banking. If you are

going in on an investment, I think what it comes down to is what society accepts to

be legitimate. If a society accepts that it is ok for the government to impound the

45 Bagus, P. (2015). In Defense of Deflation. Springer.

“The hardest form of money is

one with constant money supply

and zero elasticity.”

Philipp Bagus

“Some of the most important

technological, medical, economic,

and artistic human achievements

were invented during the era of

the gold standard, which partly

explains why it was known as la

Belle Epoque, or the beautiful

era, across Europe.”

Saifedean Ammous

Page 40: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

40

Twitter: @CryptoManagers

property of the borrower if they can’t pay back, then effectively you are monetizing

the property of the borrower, which is the collateral. Thus, you are effectively

monetizing the collateral. Interest lending carries collateral that can be impounded

and repossessed by the bank. Effectively, it makes the certain asset monetized

because you have issued a loan backed by that asset which is not money, it is a

house or car or a piece of land. That kind of business model is only accepted in

places when it is fine for the government to impound that property when the

borrower defaults. On the other hand, if the borrower’s collateral cannot be

impounded, then lenders often reject these kinds of deals and banks do not engage

in them.

Figure 11: Are US Equities indicating the next Recession?

Source: Yahoo Finance, Incrementum.

In a world where banks can only lend deposits or invest in direct equity and they

cannot repossess collateral, then the bank cannot make guarantees obviously,

because there is always a risk in business. Since the bank cannot create money

from fractional reserves and must first bring in money deposits from clients, they

cannot guarantee the solvency of their depositor accounts. So, the depositors are

accepting unlimited downside of complete default of the bank, and the bank is

asking them to accept limited upside. So, the notion of interest without risk

of default is untenable in that kind of world. Nobody would put their money

with someone who tells you,

“It is often in a country’s long-

term interest to give up political

control over its currency.”

Princess Gisela von und zu

Liechtenstein

0

2B

4B

6B

8B

10B

12B

1970 1980 1990 2000 2010

0

500

1000

1500

2000

2500

3000

S&P 500 Index (USD) Volume (USD)

Page 41: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

41

Twitter: @CryptoManagers

“If we lose, you lose all your money and if we win you only get 3 %.

Consequently, everybody would go into equity investments. Either you put

money into a bank as a deposit available for maturity in which case you pay

the bank a fee for the storage and for making the money available for you. Or

if you have money that you are willing to sit on, you invest it as equity in

some other business and it is the job of the bank to match maturities between

the borrowers and the lenders.”

Saifedean Ammous

Although, Mark Valek does not agree with Saif 100 %, he thinks that in addition to

full deposits and equity investments there will also be demand for debt

instruments or deposits. “I think also in a zero-inflation monetary system there

would definitely be demand for investments not only in equity but also in debt. A

differentiated capital structure of a company enables different payout

characteristics for investors. Low returns on bonds or also lending accounts at

banks, enable the investor to receive predictable cash flows with higher seniority in

case of bankruptcy. It’s important to note that these would not be riskless

investments.”

However, in this monetary system, investors would not necessarily need to risk

their Bitcoin in a security investment, such as stocks or bonds, but they would still

experience an appreciation of the currency in form of a real increase in the

purchasing power of money. If investors do lend out Bitcoin to a bank or financial

intermediary who pools the risk of their borrowers, then the bank should pay a fee

to the depositor for accepting counterparty risk.“ So, there may be a case for such a

thing as a low-risk interest rate investment but probably the tendency would be

much lower to take this kind of risk. This is just a minor disagreement,” Mark

adds.

Table 2: Bank Account Options Under a Global Bitcoin Standard.

Bank Account Options for Depositors Saifedean

Ammous

Mark

Valek

Full reserves available on demand – depositor pays bank/depositor for storage and optionally

insures deposit. Investor earns from appreciation of currency over time.

Depositors invest directly in equity. Investor earns positive or negative return and owns equity

shares.

Depositors deposit money in bank in a certificate deposit or bond. Bank pools borrower risk

and lends matched maturity loans. Bank pays yield to depositor.

Source: Saifedean Ammous Interview, Incrementum AG.

Mark responded to the full reserve argument with the common critique posited by

mainstream economists, “Will a deflationary monetary system hamper

growth like the Keynesians claim?” Mark holds that a debt-based monetary

system needs inflation in order to stimulate research, development, expansion, and

intervention. However, under the classical gold standard, capital markets still

existed. Even though there was some kind of gold flow or inflation, the productivity

was higher than the inflation rate of gold.

“For something to assume a

monetary role, it has to be costly

to produce, otherwise the

temptation to make money on the

cheap will destroy the wealth of

the savers and destroy the

incentive anyone has to save in

this medium.”

Saifedean Ammous

Page 42: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

42

Twitter: @CryptoManagers

Saif on Investing in Bitcoin

Question: What do you think about smart contracts and utility

tokens that can facilitate decentralized capital markets?

Answer: Bitcoin is all we get, we have to learn to accept it.

Question: If you were to create a cryptocurrency fund, would you

allocate 100 % of the portfolio to Bitcoin?

Answer: I would not create a cryptocurrency fund,

because the only cryptocurrency investment you need is

to just hold the Bitcoin.

Question: What are your thoughts on how to make an initial

investment in Bitcoin? Would you buy with cost-averaging over

time or would you put your entire investment in the market at

once?

Answer: Bitcoin is a highly risky asset. I would not advise

putting a lot of money into it. I always have to keep telling

people, this could still blow up. It has only been around

for 10 years. Bitcoin might not work, or it might go

through a bear market for another 10 to 20 years. Even in

the best-case scenario, Bitcoin will be highly volatile, and

it is going to have some massive drops. Among

cryptocurrencies, I think that Bitcoin is the only one that

might stay as a long-term hedge against monetary

inflation.

“Yes absolutely,” Saif believes. “In order to create interest in a debt-based system,

the bank monetizes the collateral, and in order to run fractional reserve banking, it

allows a central bank to create money and a fractional reserve system would

be unstable without a central bank. The central bank can become more

inflationary by manipulating interest rates downwards, which enables the

government to borrow and spend more. There are different layers of inflation, and

the key is to create parts of the economy that are dependent on this credit money.

They end up with all these industries and all these people employed because of that

money; they are politically connected, and they need to keep that money going.

This is a bug, not a feature, you would want to get rid

of that, you would want to make it that there is no

money creation going on so that investments have to

come from real saving. In this case, you would have

an actual functioning capital market. Maturity

matched.”

A Free Market for Money

Transitioning to the future outlook for the money

market, Demelza asked, “If all the central banks

around the world respond to Bitcoin by decreasing

the flow of their currencies and making their

currencies harder, do you think that Bitcoin and

central bank-issued fiat currencies will

compete alongside each other like Uber and

taxies or Airbnb and hotels? Or do you think one is

going to completely substitute the other?”

Saif’s answer: “For the first time, people have

an alternative; they can opt out of central

banking. This was not possible before Bitcoin,

but it is possible now. Bitcoin will limit the ability

all these government from inflating. You can imagine

Bitcoin developing a so-called monetary Batman

that is hanging in the shadows of every central

bank and is waiting for that central bank to

begin inflating the money supply, and then

people in that country would jump into

Bitcoin. When they jump to Bitcoin, its value will

significantly appreciate.

Saif thinks it is good to think of Bitcoin as a small side bank account

that you have for a rainy day. He said, “The important thing is that you may be

stuck in a country one day where you got robbed, you don’t have access to your

bank account, and you do not have money. If you have Bitcoin, you can get out of

Page 43: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

43

Twitter: @CryptoManagers

trouble by buying an airline ticket with it. I think it is important to

understand the value proposition.”

Mark echoed Saif. “We are very much on the same page because, even though we

are optimistic, I think that from a portfolio point of view investors do not have

to allocate a huge amount to have an impact. Investors can allocate a low-

digit percentage, even as low as 1 percent of their entire net wealth, and it

will have a huge impact if Bitcoin monetizes. Mark explains that Bitcoin is a

binary investment. Either Bitcoin becomes some kind of monetary asset and store

of value, or Bitcoin will be succeeded by something else and the price will go to

zero.

Bitcoin: Two Paths to Monetization

If we muse about the future, how will the transition from being a store of value to a

unit of account look for Bitcoin? Mark Valek considers two scenarios:

Positive scenario: Bitcoin becomes a reserve asset for central banks. A

domino effect could prompt more nations to buy Bitcoin to protect

against speculative attacks and to ensure that public debt can be paid off

with investments in Bitcoin. The Marshallian Islands already have

investment in Bitcoin, and the Central Bank of Barbados wrote a paper

on the topic in 2015.

Negative scenario. Loss of confidence in the fiat system, and there will

be a huge rush into the new safe haven being Bitcoin.

On the other hand, Saif sees a scenario in which Bitcoin ascends into monetary

supremacy by each person slowly transitioning to Bitcoin. “Just a monetary

upgrade. Install healthy software on a crappy windows PC, and it starts functioning

better. The monetary system that we have creates money when debt is

created. The flipside of that is that it destroys money when debt is paid off. We

have had this sort of system for the past 40 to 50 years, and now we have another

alternative, and everybody will jump into this new system (Bitcoin). Eventually,

people can use Bitcoin to pay off their fiat debt. If we just keep paying off our debt,

an orderly unwinding of the global monetary fiat system will ensue. Basically,

everyone pays off all of their debt and the money supply contracts until

it drops to zero, and then a new monetary system that is functional takes over

the world. It might be slow or quick, but it doesn’t have to be messy and ugly.”

“Government money is similar to

primitive forms of money and

commodities other than gold, in

that it is liable to having its

supply increased quickly

compared to its stock, leading to

a quick loss of salability,

destruction of purchasing power,

and impoverishment of its

holders.”

Saifedean Ammous

Page 44: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

We are leaders of change in the finance industry. It is our vision to make crypto assets as accessible as the stock market and

facilitate exciting new crypto ventures.

+41 44 512 7507 GENTWO Digital AG | Crypto Valley LabsDammstrasse 16 | CH-6300 Zug [email protected] www.g2d.io

Securitization of all crypto assets.

Making Crypto Assets Bankable

We make any token, ICO, STO, crypto asset or crypto portfolio investable, fully bankable and transferable in a Swiss Security (Swiss ISIN)

The crypto asset industry set out to challenge the traditional finance sector. Talent, ideas, and capital flocked to crypto assets yet for

many investors, access remains a challenge.

Seed capital was earmarked for these new opportunities but the majority of funds remains trapped in the old system.

Banks, large scale/ institutional investors are missing out.

We are the bridge between these two worlds.

Page 45: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Institutional

Requirements for an

Investible Crypto Index

“Creating an index that accurately tracks the market requires consideration of three main factors: reflecting

market dynamics, maintaining/governing the respective rules, and preventing manipulation.”

Patrick Valovic

Key Takeaways

Indices that act as benchmarks must be investable and replicable.

In order for institutional investors to be able to invest, crypto currencies must be able to be

held in custody by professional custodians.

The LY Incrementum Krypto Index takes into account the requirements of institutional clients

with regard to investability and replicability.

Authored by LIMEYARD

LIMEYARD is a Swiss index provider with offices in Zurich, New York, and Vienna. LIMEYARD focuses on both

proprietary and nonproprietary indices and combines cutting-edge index innovation with a state-of-the-art cloud-

based technology. Its fast-growing family of global equity and cryptographic assets indices is rules-based,

compliant, traditional, and provides smart-beta investable solutions for institutions on the sell side and on the

buy side. LIMEYARD entered into a joint venture with Wiener Börse AG in February 2018.

Page 46: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

46

Twitter: @CryptoManagers

Creating a Benchmark for a Premature Market

The complex cryptoasset market environment inspired a joint innovation between

LIMEYARD and Decentriq, two Swiss-based companies. They combined their

expertise to develop a comprehensive cryptoasset index aimed at capturing the

dynamics of the overall cryptographic assets market whilst dealing with unique

regulatory and economic challenges embedded in this premature market. For

investors, an index must be tradable, meaning that liquidity and rebalancing are

feasible. Furthermore, the cryptographic assets market presents specific challenges

regarding regulatory requirements, such as the exclusion of investments in

privacy coins or coins that are only traded on one exchange.

Active asset managers typically use a benchmark to measure

the performance of their portfolio in relative terms. They assess

market efficiency and price systemic risks using benchmarks. Prior to

setting up a fund strategy, asset managers apply various risk models and

compare the past performance of the strategy against the underlying

benchmark, long-term outperformance being their aspired goal. The

benchmark itself is performance-agnostic.

Passive asset managers (e. g., ETF providers), on the other

hand, invest into a portfolio which tracks an index. Their

underlying question is: what new strategy, theme, region, sector, etc.

could be a great investment opportunity for investors? The ETF provider

simply tracks a factor/risk model-based index, e. g., a low volatility index,

a momentum index, a quality index, etc.

For active and passive managers, “tracking the market” has the same meaning;

however, for the latter, the index concept reflects an investment strategy. In other

words, active managers use the benchmark to track the market as a whole, and is

therefore performance-agnostic, as long as the performance is in line with

the overall performance of the market. On the other hand, for passive investors

the index represents an investment strategy with the clear ambition to

achieve long-term positive performance. In both cases, the index is rules-

based, meaning it’s not subject to discretionary decisions.

Creating an index that accurately tracks the market requires consideration of three

main factors: reflecting market dynamics, maintaining/governing the

respective rules, and preventing manipulation.

Reflecting market dynamics: This requires compliance with data

sufficiency, as data are the main ingredient of every benchmark.

Insufficient availability of data bears the risk of not adequately

representing a market.

Maintaining/government rules: To be fully rules-based and

transparent, the methodology of an index has to be applicable under all

market circumstances avoiding the necessity for a discretionary

interference.

“Virtual Currencies may hold

long-term promise, particularly

if the innovations promote a

faster, more secure and more

efficient payment system.”

Ben Bernanke,

14th chairman of the Federal

Reserve

Page 47: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

47

Twitter: @CryptoManagers

Manipulation prevention: Internal operational processes have to be

designed to prevent index manipulation (last experienced with the

LIBOR scandal in 2011). IOSCO, the international body of the world’s

security regulators, defined the IOSCO Principles for Financial

Benchmarks, consisting of 19 principles for index providers to adhere to,

all of which are implemented in LIMEYARD’s governance structure and

audited on an annual basis.

The Creation of the LIMEYARD Cryptoasset Index (LYCAI)

LIMEYARD and Decentriq faced two main challenges when creating a

comprehensive cryptographic market index: How to handle (1) a highly dynamic

market with numerous, partly unknown factors influencing its overall development

and (2) practical requirements of a benchmark that make the index rules-based,

transparent, and compliant. The result of this challenging endeavour is the

LIMEYARD Crypto Assets index (LYCAI), consisting of the largest 20

cryptoassets that are publicly tradable.

Figure 12: Index Performance LYCAI vs. Bitcoin.

Source: LIMEYARD.

To be part of the LYCAI, an asset has to fulfil several parameters to ensure

sufficient robustness, liquidity, and tradability. The index is calculated in real-

time 24/7, using trading data from eight different exchanges. The

aggregation over several trusted exchanges improves robustness against exchange-

level failures and price manipulations, providing an adequate representation of the

underlying market. The selected exchanges have, among other things, a

comparably high monthly liquidity. LIMEYARD is only considering assets that are

traded on at least two trusted exchanges. This ensures that, if one exchange

experiences any technical issue, the index can continue to pull price data on the

full predefined set of assets. The price data aggregation algorithm factors in both

volumes and outliers, reducing undesired spikes in the index level which could

happen in a young and fragmented market. Additionally, only the assets that are in

the top 60 % in terms of trading volume are eligible for inclusion in the index.

“There are three eras of

currency: commodity based,

politically based, and now, math

based.”

Chris Dixon

Page 48: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

48

Twitter: @CryptoManagers

The index considers only those assets whose protocols are not designed to enable

anonymity, avoiding the risk of being associated with illegal transactions and

maintain a certain degree of transparency for taxation purposes. With this

criterion, LIMEYARD and Decentriq anticipated concerns by regulators and aimed

to limit the infringement of KYC/AML standards when using the LYCAI as an

underlying for financial instruments. To provide diversification and compensate

the high skewness of the market through Bitcoin, the index smoothes each

constituent’s market capitalisation by an exponential moving average over the

month prior to the relevant review date. The weights are then derived from a

sigmoid function which penalises high values without imposing a hard cap.

As a result of the weighting methodology, an allocation of large assets is well-

balanced compared to other indices. For instance, Bitcoin and Ethereum’s weight

as of the end of October 2018 corresponds respectively to 39.30 % and 17.80 %

compared to more than 60 % and 13 % for the Crypto Market Index 10 and 30 %

(cap) and 23.46 % for the Bloomberg Galaxy Crypto Index.

Figure 13: LYCAI Asset Allocation November 2018.

Source: LIMEYARD.

The LYCAI index is the true benchmark for measuring fund performance by

cryptographic asset managers. The index meets all IOSCO requirements and the

regulators’ current concerns that they have explicitly stated regarding cryptoassets.

Incrementum Investible Cryptoasset Index

Different clients have different requirements. For this reason, we

tailored the LY Incrementum index to Incrementum’s requirements.

The LIMEYARD Crypto Asset Index is the basis concept for the LY Incrementum

Index, with the following deviations:

Coins in the index must be able to be stored in cold storage using

hardware in order to be insured by Swiss insurance companies.

Coins must have market capitalisation of more than $500 million.

The number of assets is fixed at ten in order to reduce rebalancing

transaction costs.

“Well, I think it is working. There

may be other currencies like it

that may be even better. But in

the meantime, there’s a big

industry around Bitcoin. —

People have made fortunes off

Bitcoin, some have lost money. It

is volatile, but people make

money off of volatility too.”

Richard Branson

Page 49: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

49

Twitter: @CryptoManagers

Figure 14: Index Performance LYCAI vs. Incrementum Index

Source: LIMEYARD.

This slightly revised index concept proves to be very solid resulting in a one-year

return of 16.10 % compared to LYCAI’s 0.58 % one-year return. The one-year

annualised volatility is 96.49 % compared to LYCAI’s 97.06 %. The one-year

volatility is, of course, mainly driven by Bitcoin, the largest asset in both indices.

The lower number of assets in the LY Incrementum Index makes the index more

tradable compared to the 20 assets in the LYCAI, which is designed to primarily

represent the overall crypto market.

Final Remarks

The Bitcoin market is entering a more mature state. Relevant markets are

regulated (e. g., CBOE) with rules designed to prevent potential manipulation.

There is a steady growth of Bitcoin futures traded on the CME platform to

currently more than $162 million average daily volume (ADV). Various leading

investment banks and traditional exchanges run internal projects to further evolve

the maturity not only of Bitcoin, but also of other large cap digital assets. Many

projects have already been announced, others are expected to be announced very

soon. That’s why LIMEYARD continues to invest into strategic partnerships and

the development of a broader crypto index family, also covering investment

strategies for the passive asset management segment, derived from its leading

LIMEYARD Crypto Asset Index methodology.

“PayPal had these goals of

creating a new currency. We

failed at that, and we just

created a new payment system. I

think Bitcoin has succeeded on

the level of a new currency.”

Peter Thiel

Page 50: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Equity Tokens

“Fractional ownership is not unique to blockchain, in fact, it’s not even unique to this century. Joint ownership dates

back to the Roman Republic, or the Dutch East India Company in more modern times. However, some assets

classes such as commercial real estate and fine art continue to be characterized by high unit costs.

A typical retail investor cannot harness the resources required to buy a Manhattan high rise. The investor is left

with two options: (1) Forego exposure to Manhattan commercial real estate in their investment portfolio, or (2)

gain exposure through an intermediary, for example a publicly traded Real Estate Investment Trust (REIT), where

it is often bundled with a portfolio of other buildings of varying quality and characteristics. Security tokens offer an

efficient path to fractionalize a single high value asset.”

Stephen McKeon, Professor University of Oregon

Key Takeaways

Equity tokens enable companies to raise equity using blockchain technology without locking up

investors.

Issuers of securities tokens are seeking to access the large pool of institutional money that has

not yet penetrated the crypto currency market. Institutional investors expect KYC/AML, data

protection and see a hurdle in one of the core elements of the blockchain, namely its

immutability.

In 2019 there will be a race between stock exchanges, which can offer the first regulated market

for securities tokens.

Page 51: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

51

Twitter: @CryptoManagers

The Austrian Financial Market Authority approved the first financial

prospectus for a fully regulated tokenized security in the European

Union in late November. The Financial Market Authority in Liechtenstein

already approved Liechtenstein’s first security token in August. Mt. Pelerin,

Tokenestate, and Securosys are also purportedly offering security tokens in

Switzerland. This means that a cryptocurrency can represent legal ownership in a

company or can represent other securities, such as certificates and bonds, if they

also register as a security. Unfortunately, there are no cryptocurrency exchanges

that are licensed to trade security tokens. However, equity tokens are not for the

standard cryptocurrency investor. Instead, equity tokens are trying to

access the large pool of institutional money that has not entered the

cryptocurrency market yet.

Institutional Money-Steering Innovation

The public blockchain technology reduces the cost of raising capital, and this

matters for small firms. One of the main benefits of trading digital assets on the

public blockchain infrastructure is that anyone can issue a digital asset, and

anyone can invest in a digital asset. This saves immense amounts of time and

money for issuers who no longer need licenses, underwriters, or lawyers. The large

cost of listing a company on a stock exchange erects barriers to entry for small and

medium-sized enterprises (SMEs). The blockchain also removes the barriers to

entry posed by regulations that limit investment possibilities for retail

investors like grandma.

In addition to enabling financial inclusion in the market, the public blockchain

technology allows investors to trade “shares” of companies for much lower

fees with instant settlement times. This means significant savings for retail

investors and smaller profits for stock brokers.

However, some investors, especially institutional investors, want features of the

traditional capital market to be incorporated into the token market. Enter

“Security Token”. Over the past few months, the term “Security Token Offering”

(STO) has been growing in importance compared to initial coin offerings. There

are three main problems institutional investors have with the Wild West of

blockchain:

Not all cryptocurrencies follow the laws such as know-your-customer,

anti-money laundering, sanctions, etc.

Large investors want privacy. They do not want transparent blockchains

that allow outsiders to see their transaction amounts and destinations.

Immutability. Public blockchain cryptocurrencies are impossible to

retrieve if a private key is hacked or lost. Large investors will not want

their shares of Visa stock being controlled by a private key. Instead,

cancel and reissue features will be required before the security token

market can gain adoption.

“Blockchain with improved

scalability will increase

efficiency in many areas:

logistics and supply-chain

control, healthcare, public

administration (for land, car and

company registries), smart

contracts and more. In the

financial industry, it might

replace some banking functions,

such as payments, custody and

accounts – even independent of

cryptocurrencies.”

Princess Gisela von und zu

Leichtenstein

“Just as it got easier to use

email, it will be easier to use

Bitcoin as people invest in it

and become more familiar with

it.”

Gavin Andresen,

core developer of Bitcoin

Page 52: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

52

Twitter: @CryptoManagers

In order to manage these concerns, several companies are working on private

blockchains that will allow equity tokens to be stored and traded. The Swiss stock

market’s Swiss Digital Exchange (SDX) near Sihlcity is working on a pilot project

that wants to tokenize four main groups of assets.

First, native tokens for SMEs that only exist on SDX will be issued,

stored, and traded.

Second, tokenize existing securities on the SIX Swiss Exchange.

Third, tokenize non-bankable assets.

Fourth, tokenize cryptocurrencies, such as Bitcoin and Ethereum.

In addition to SDX, Daura, a partnership between MME and Swisscom, is also

working on a private blockchain. Blockchains specifically designed for trading

securities will have KYC/AML integration, privacy, and cancel and reissue features

that allow the stock exchange owner or broker to reissue shares to companies that

lost their private keys or were hacked. Blockstream’s LIQUID and Polymath are

also both examples of blockchains targeting the security market. However,

important legal issues, such as whether or not tokenizing a fund violates fund

distribution rights, still need to be answered.

Figure 15: Public Security Token Platforms Performance.

Source: Incrementum

Define Token and Security

A token is a digital representation of value on a particular distributed

ledger. Tokens can represent voting rights, ownership shares, bonds, and much

more. ERC 20 smart contracts on the Ethereum Blockchain and NEP5 smart

contracts on the NEO blockchain are currently being used to pay out company

dividends and vote on managerial decisions. On the other hand, the definition of a

security differs from jurisdiction to jurisdiction. In the US, a financial product is

legally classified as a security if the four following criteria are met:

“Liechtenstein is likely to be a

pioneer, advancing pragmatic,

innovative regulation and

supervision for cryptocurrency

transactions and ICOs.”

Princess Gisela von und zu

Liechtenstein

Page 53: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

53

Twitter: @CryptoManagers

Investment of value

With an expectation of profit

In a common enterprise

With the profit to be generated by a third party

As mentioned in the next chapter, these criteria came from the 1946 Supreme

Court case between a Florida citrus grower named Howey and the Securities

Exchange Commission. In response, US cryptocurrency issuers are applying for

Reg D. and Reg S. exemptions from security law. They are also exploring how

Airdrops can circumvent security law.

However, Europe does not have any concept of the Howey test. This is

because the US has common law where court cases set precedents for future

judgements. In contrast, mainland Europe has civil law, which is a principle-based

approach to law. According to Article 2 let. b FMIA in Switzerland, a security is

defined as, “standardized certificated and uncertificated securities, derivatives and

intermediated securities, which are suitable for mass trading.” Subsequently,

FINMA has already reported that many cryptocurrencies are

securities.46

Should I Tokenize or Securitize or Both?

Tokenization of assets existed before cryptocurrencies were created.

They are called certificates. However, certificates cost money to set up and

maintain. Unlike issuing an ERC token on Ethereum, certificate issuers must have

a business structure that can legally issue structured products, and often

certificates are limited to qualified investors. According to the Swiss Collective

Investment Schemes Act (CISA) of 2006, a qualified investor is one of the

following47:

Supervised financial intermediaries (such as banks, securities dealers

and investment fund managers)

Supervised insurance companies

Public law institutions and pension funds with professional investment

operations

Business enterprises with professional investment operations

Wealthy private persons (German: vermögende

Privatpersonen) with CHF 2 million worth of financial assets,

and direct real estate investments do not count!

46 See Wegleitung für Unterstellungsanfragen betreffend Initial Coin Offerings, FINMA, February 16, 2018.

47 See “Qualified Investors,” Swiss Fund Data AG, 2018.

“There will be many types of

assets codified into the

blockchain, and they are all not

just going to be on the Bitcoin

blockchain – it’s going to be a

number of different assets here.

And the best way to invest in that

is a diversified portfolio.”

Olaf Carlson-Wee

Page 54: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

54

Twitter: @CryptoManagers

Investors who have a written asset management agreement with a

supervised bank, securities dealer or investment fund manager

One type of structured product is a certificate. A certificate can be a tracker

certificate that tracks the value of an asset, or a certificate can be

actively managed. The asset could be an IBM share or a cryptocurrency index,

or a physical plane, for example. Bank Vontobel, for example, creates many

certificates. A certificate is similar to a bond because it represents a predetermined

payoff promise that the issuer gives to the investor. This means that the investors

can read in the terms of conditions what they will get from the certificate when the

certificate expires. For example, the promise could be that “In two years you get

the performance of IBM shares.” However, certificates can be actively managed as

well. Actively managed certificates (AMCs) can contain any type of cryptocurrency,

including privacy coins, pre-ICO coins, and ICO coins. Investment managers can

also employ riskier strategies than UCITS or AIF can such as shorting and taking

leverage.

Certificates are like tokens in the sense that they can be used to

securitize anything. The only difference is that certificates contain normal

investor protections and they can be easily purchased through security brokers.

Since they adhere to existing regulations, they have certain costs. Therefore,

securitization of an asset using a certificate only begins to make sense for assets

worth over ₣ 10,000. Unlike UCITS and AIF regulated cryptocurrency funds, such

as Incrementum’s, structured products are exempt from the collective investment

scheme regulations.

Figure 16: SIX Assets Growth in Millions of Swiss Francs.

Source: SIX, Incrementum

“It’s bigger than the Iron Age, the

Renaissance. It’s bigger than the

Industrial Revolution.”

Tim Draper

2000 2005 2010 2015

0

1M

2M

3M

4M

5M

6M

Swiss All Shares Index SPI EXTRA Total Return Swiss Performance Index SPI®

SMI Expanded Total Return  SMI MID Total Return Swiss Market Index SMI®

Page 55: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

55

Twitter: @CryptoManagers

GenTwo Digital, a joint venture of GenTwo AG and

Inacta, is a Swiss consultancy firm based in Zug.

GenTwo Digital was founded by Patrick Loepfe, a

previous Vontobel Deritrade specialist, and the Vice

President of the Board or/and Managing Partner of

Forstmann, Philippe A. Naegeli. In an exclusive

interview with Patrick Loepfe from GenTwo, we

discussed the innerworkings of how securitizing a

cryptocurrency works. The company helps financial

intermediaries, high net worth individuals, and

family offices turn bankable assets, such as actively

managed accounts and structured products, and non-

bankable assets, such as art and cryptocurrencies,

into tradable certificates with Swiss International

Securities Identification Number (ISIN) numbers. An

ISIN number is code that uniquely identifies a

specific securities issue. In Switzerland, obtaining an

ISIN code for a security requires a prospectus, term

sheet, and offering memorandum. In traditional

finance, ISINs are used for stocks, bonds, funds,

hedge funds, mutual funds, and other securities,

whether for a private offering or going public with an

IPO (initial public offering).

What GenTwo does is build a financial company for

each investment manager, and then the investment

managers can issue multiple certificates within the

company. GenTwo’s issuing structure is a unique

dedicated issuance vehicle in Guernsey. Once

GenTwo sets up the special purpose vehicle company,

investment managers can build structured products

as they wish. The advantage of setting up a dedicated

issuance vehicle is that issuers can have balance sheet

control where liabilities are stored off the balance

sheet. Normally, issuers risk balance sheet risk from

holding assets on the active side and liabilities that

can be impacted from operational issues. Instead, an

SPV structure leaves only the assets on the active side

of the balance sheet and the certificates on the passive side. Since the certificate

tracks the value of the assets that are held on the active side, there is

almost no risk of a default. For example, Bank Vontobel has an SPV in Dubai

from which they issue their certificates. Julias Bär has a SPV in Guernsey, EFG has

a SPV in Guernsey.

Advantages and Disadvantages of Certificates vs. Funds

for Cryptocurrency Asset Managers

Advantages

First. Unlike Alternative Investment Funds, Guernsey

special purpose vehicles do not need to have external

custodians that have a bank license. Therefore,

investment managers can outsource cryptocurrency

storage to third party custodians like the companies

mentioned in “Crypto Concepts: Custody” in the

December 2018 edition of The Crypto Research Report.

Second. Lower fees. Since managers of Actively

Managed Certificates can execute trades with the

counterparties of their choosing and outsource

cryptocurrency custodianship, fees can be less than with

UCITS or AIF cryptocurrency vehicles that need to work

with banks and administrators.

Third. Time. SPVs take 10 business days to setup

and certificates take 3 business days.

Disadvantages

First. Cryptocurrency securities are not always invested

in the underlying cryptocurrency. They can just be

trackers. Investors should verify if the security is actually

invested in the underlying.

Second. Unless the cryptocurrency security uses a

licensed bank or third-party custodian that offers

insurance, most cryptocurrency holdings are uninsured.

Unlike alterative investment funds that have liable

custodians, structured products and managed accounts

can have a range of options from completely uninsured to

fully insured.

Third. Swiss Certificates are not always passportable to

the European Union.

Page 56: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

56

Twitter: @CryptoManagers

Certificates are not really competitors for tokens. Tokens can be issued by

retail investors and anyone in the world can invest in them. At Incrementum, we

suspect that one will not completely replace the other for the time being. Instead,

some market participants will choose to invest in the regulated world and other

market participants will choose to invest in the unregulated world. Many

companies will raise capital in both markets. As Oliver Völkel said during the

Crypto Christmas Market Outlook, the main problem with equity tokens is that a

licensed exchanged where investors can trade these assets does not exist. 2019

will be a race for the first legal platform that can trade

cryptocurrencies that represent securities.

Disclaimer: GenTwo is an official partner of the Crypto Research Report. None of

the information you read in this article should be taken as investment advice, nor

do the writers of the Crypto Research Report endorse any project that may be

mentioned or linked to in this article. Please do your own due diligence before

taking any action related to content within this article.

“One of the most powerful use

cases of blockchain technology

was to inscribe immutable and

transparent information that

could never be wiped from the

face of digital history and that

was free for all to see. Satoshi’s

choice first to employ this

functionality by inscribing a note

about bank bailouts made it

clear he was keen on never

letting us forget the failings of

the 2008 financial crisis.”

Chris Burniske,

author of Cryptoassets

Page 58: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Legal Challenges for

Blockchain-Based

Capital Markets

“Blockchain technology can achieve what governments wanted to achieve for a long time: a fair, secure and

attractive capital market for start-ups, SMEs and investors.”

Christian Meisser, LEXR AG

Key Takeaways

Tokenization seems to be interesting for small and medium-sized enterprises, as the cost of

raising capital via tokens is sometimes lower than on the traditional capital market.

The regulatory classification of whether an issued token represents a security has far-reaching

implications and is of the utmost legal relevance. The assessment of whether a token is to be

treated like a security under supervisory law is fundamentally different in various

jurisdictions.

Authored by Christian Meisser, lic. iur., MBA, CEO of LEXR AG

Christian Meisser is an entrepreneur and lawyer with a focus on the intersection

between technology and law. He regularly speaks, publishes, and advises on

blockchain-related topics and is specialized in financial market regulation. After

working for some of the world’s top law firms, he founded the LegalTech company

LEXR AG with the vision of providing like-minded entrepreneurs with price-

predictable legal services that are tailored to the way companies operate and

innovate today. Photo: Christian

Meisser

Page 59: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

59

Twitter: @CryptoManagers

Capital Flows to the US

Start-ups as well as small and medium-sized enterprises (SMEs) are praised for

being a driving force of economic growth. In principle, Europe offers excellent

conditions for growth, with a mobile and well-educated talent pool, a huge

domestic market, and modern infrastructure. Nevertheless, risk capital for start-

ups is scarce and promising start-ups move abroad. According to a press release of

the European Commission,48 in 2016 venture capital providers invested

only € 6.5 billion in the entire EU, just about one sixth of the € 39.4

billion invested in the US. According to the same release, only 26 European

companies were regarded as “unicorns” at the end of 2017 (unlisted

companies with a theoretical market capitalization in excess of $ 1 billion), while

109 such companies existed in the US and 59 in China.

Not only start-up funding but also financial market support for SMEs appears to

be lacking. One reason why start-ups are left wanting is widely considered to be the

lack of “exit” opportunities in the form of listings: in 2017, the number of European

IPOs of SMEs was still down 50 percent from the time prior to the financial

crisis.49

Figure 17: ICOs vs IPOs vs VC Funds raised (US).

Source: ICOdata.io, CBInsights, Incrementum

48 See “EU: €2.1 billion to boost venture capital investment in Europe's innovative start-ups” [press release],

European Commission, April 10, 2018.

49 See Building a proportionate regulatory environment to support SME listing [public consultation], European

Commission, 2017.

“The blockchain is the financial

challenge of our time. It is going

to change the way that our

financial world operates.”

Blythe Masters

Page 60: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

60

Twitter: @CryptoManagers

With public markets for SMEs weak, venture capital firms hesitate to

invest in SMEs at all. While the EU tries to improve the situation with

subsidies, harmonization of capital markets and mild deregulation, the

world of start-up funding is fundamentally changing because of the blockchain

technology. The possibility of transferring assets directly between two parties

without intermediaries enables an enormous simplification of issuance and trading

of capital market instruments. Thus, start-ups raised $ 5.5 billion worldwide in

2017 by issuing tokens in the framework of ICOs – and this year the total amount

has already swelled to $ 14.3 billion.50

But not only primary markets (i.e., the initial issuance of ICOs) are thriving. Daily

trading volume in tokens in secondary markets amounts to several

billion USD.51 Thus, blockchain technology has already furnished impressive

proof of its application potential in capital markets. From the perspective of

investors, it was evidently worth the risk – according to one study, the average

return on investment on ICOs stands at 82 %.52 However, the legal design

of such tokens as this new technology emerges has received little attention so far

and investors rarely enjoy enforceable rights. The trend is clearly moving

toward issuance of so-called security token offerings: more and more ICO

teams want to tie tokens to enforceable rights, which provide token

owners with a legal position akin to that of shareholders. Thus, the vision

of a capital market in which start-ups and SMEs are able to access needed growth

capital without having to move offshore and which offers investors safe and simple

access to diversification opportunities is coming within grasping distance.

This article presents legal challenges for effective blockchain-based capital markets

in different countries by way of examples and in particular discusses the following

subjects:

Challenges posed by the classification of tokens in financial

market regulations

Legal preconditions for the issuance of security tokens

Legal framework conditions for trading in security tokens

Classification of Tokens as Securities

Classification of tokens within the existing framework of civil law is already quite

difficult and the opinions of legal scholars differ widely: for instance, in

Switzerland it is debated whether tokens are digital assets, contractual rights,

50 Figures according to Coindesk ICO Tracker, accessed September 19, 2018.

51 Figures according to CoinMarketCap, accessed September 19, 2018.

52 See “Digital Tulips? Returns to Investors in Initial Coin Offerings,” Hugo Benedetti and Leonard Kostovetsky,

SSRN, May 20, 2018.

“Blockchain technology isn’t just

a more efficient way to settle

securities. It will fundamentally

change market structures, and

maybe even the architecture of

the Internet itself.”

Abigail Johnson

Page 61: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

61

Twitter: @CryptoManagers

or a special form of assets in their own right.53 This represents a difficult

task for regulators with respect to a legal assessment in terms of financial

legislation. Obligations under financial market regulations with respect to the

issuance and trading of tokens directly depend on their legal classification. For

example, if tokens are classified as securities54 under a specific legal order, public

offerings of such tokens without an appropriate prospectus may make

issuers liable to criminal prosecution. Accordingly, correct classification is

quite important, but it is anything but trivial: not unlike a blank sheet of paper,

tokens can be configured with any combination of rights and obligations, or in the

framework of smart contracts even with complex, automated processes. Various

countries are trying to meet this challenge in very different ways:

Figure 18: Google Trends - Security Token Offerings are Gaining

Interest

Source: Incrementum

The approach that has been historically established in US case law is based on

flexible rather than static principles, which makes it possible to adapt regulations

to the countless different possible designs.55 This is primarily based on the

Howey Test and the term security is tied to whether “an investment in a

common venture is premised on a reasonable expectation of profits to be

derived from the entrepreneurial or managerial efforts of others.” Whether there

is indeed “a reasonable expectation of profit” is sometimes questionable,

particularly in ICO projects which refrain from according any rights to investors.

Supervisory authorities can strengthen legal certainty by regularly publicizing

relevant rulings.

53 See “Verfügungsmacht und Verfügungsrecht an Bitcoins im Konkurs” ("Authority to dispose of and right to

dispose of Bitcoins in insolvency proceedings”), Christian Meisser, Luzius Meisser, and Ronald Kogens, Jusletter IT:

online, May 24, 2018.

54 The term security is used as an overarching term herein for all designations of a similar type used in different

jurisdictions, such as stocks/bonds or financial instruments.

55 See Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO,

Securities and Exchange Commission, Release No. 81207, July 25, 2017

“Over the next decade, there will

be disruption as significant as

the Internet was for publishing,

where blockchain is going to

disrupt dozens of industries, one

being capital markets and Wall

Street.”

Patrick M. Byrne

Page 62: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

62

Twitter: @CryptoManagers

The legal situation in the EU is more formal. The EU directive on markets for

financial instruments (better known as MiFID, or MiFID II) has largely

harmonized financial markets in the single European market; the term “financial

instrument” was defined in Annex I, section C. Unfortunately, it remains

essentially unclear under what circumstances a security token is

actually classified as a financial instrument. The definitions in the directive

refer to “old world” terms (i. e. before blockchain technology), which simply cannot

accommodate the plethora of possible designs associated with tokens. The Malta

Financial Services Authority has at least attempted to provide some clarity in the

form of a financial instrument test.56 Without practical examples, the

definitions nevertheless exhibit a degree of abstraction that leaves market

participants unsure if tokens are deemed to represent financial instruments in

view of the multitude of possible configurations.

The Swiss financial market supervisory authority Finma has decided on a

compromise in its ICO guidelines.57 Similar to the method adopted in the US, a

functional approach is used with respect to investment purposes. At the same time,

formal criteria are taken into account as well, and essentially every token that

represents an asset is considered a security token. Due to these

comparatively clear criteria and the possibility of asking Finma to provide

regulatory information on specific cases in advance, the legal situation pertaining

to various token configurations can be easily assessed in Switzerland.

The tokenization of traditional securities, such as stocks or bonds, is the easiest to

assess: The laws were written for these types of securities and issuers are unlikely

to face surprises with respect to tax consequences either. In order to prevent the

erection of inappropriate barriers to innovation in virtual worlds and the

tokenization of real assets, a restrictive application of the various terms

designating securities would be welcome. For example, if one were to tokenize

tickets to an event, such tokens may already be regarded as securities in several

countries: for one thing, a real asset is underlying the token, for another thing one

may well purchase event tickets for investment purposes, i. e. in the hope of being

able to sell them at a higher price at a later date. At the same time, it seems hardly

appropriate to having to issue a prospectus or to trade such tokens on a regulated

exchange.

Primary Market: Issuance of Security Tokens

From a technical perspective, the internet makes it easy to market token offerings

globally, and cryptocurrencies allow investors to buy tokens globally. Expensive

56 See Guidance Note To The Financial Instrument Test, Malta Financial Services Authority, July 24, 2018.

57 See Guidelines for enquiries regarding the regulatory framework for initial coin offerings (ICOs), Finma, February

16, 2018.

“Bitcoin can be best understood

as distributed software that

allows for transfer of value using

a currency protected from

unexpected inflation without

relying on trusted third parties”

Saifedean Ammous

Page 63: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

63

Twitter: @CryptoManagers

intermediaries such as investment banks are barely needed anymore. The rapid

growth of ICOs demonstrates that such a global capital market offers highly

attractive funding opportunities for companies. However, upon issuing security

tokens one is faced with a patchwork of national regulations. The most

important aspect in this context: potential prospectus obligations.

A prospectus is intended to provide investors with the information required to

make an investment decision. What information precisely has to be included varies

from country to country and ranges from (for the time being) a few pages in

Switzerland to almost book-sized tomes in the US. Prospectus requirements

in the EU are so demanding that small funding rounds are barely worth

the investment of time and money needed to draw up and publish a

company’s financial statements. As an illustration of the costs involved:

according to the Official Journal of the EU, the cost of drawing up an EU

prospectus for offers of securities to the public with a total consideration of less

than € 1,000,000 is likely to be disproportionate to the proceeds.58 And that is just

the prospectus for the EU. For every additional country in which tokens are to be

offered, one has to verify whether a prospectus needs to be published and/or has to

be reviewed by the local authorities.

Prospectus obligations may be limited or waived entirely below a certain threshold

and plans by a number of countries to raise such thresholds for prospectus

publication obligations have to be welcomed in this context (in the EU to around

EUR 8 million or in Switzerland to CHF 2.5 million). Further relief is to be

provided by various exemptions, such as thresholds on the number of investors or

the focus on professional or accredited investors. While prospectus obligations and

restrictions on distribution represent barriers to security token offerings, there

already exist numerous projects which are able to implement such offerings

successfully and with legal certainty. Along with growing interest, the required

know-how will spread in the marketplace and costs will be lowered further, not

least through the use of legal-tech software for drawing up documentation in

various countries.

Secondary Markets: Trading in Security Tokens

The most impressive efficiency gains are possible in trading. Thanks to smart

contracts, so-called decentralized trading platforms can be built, which enable

trading between two parties without any intermediaries or counterparty

risks. The assets to be traded are safely stored via the smart contract, and once the

required conditions are fulfilled, clearing and settlement takes place automatically

58 See “REGULATION (EU) 2017/1129 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 14 June 2017 on the prospectus to be published when securities are offered to the public or admitted to trading on

a regulated market (prospectus directive 3),” European Union, Official Journal of the European Union, June 30, 2017.

“People didn’t know where they

could trade. When everybody

owes each other IOUs that can be

in multiple places at once, that’s

how the system couldn’t tell any

more who owned what and who

owed what to whom. Blockchain

could have prevented 2008.”

Patrick M. Byrne

Page 64: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

64

Twitter: @CryptoManagers

on the blockchain. Infrastructure costs, such as centralized security depositories,

security settlement systems, or banks, and counterparty risks disappear. It is

simply not possible in such a system to be affected by a default such as that of

Lehman Brothers.

A sensible function that remains in place consists of match-making platforms

similar to those operated by stock exchanges or other trading platforms, which are

in particular aimed at efficient price formation and the prevention of market

abuse. From a regulatory perspective, risks, such as insider trading and market

manipulation, remain extant in the blockchain world as well, and modern-day

regulations are in essence applicable to trading platforms for security tokens. In

the meantime, both established exchanges such Switzerland’s SIX59 and

blockchain enterprises in a number of countries have made public announcements

regarding the development of security token trading platforms. As “old-world”

regulations remain applicable, a license is necessary, which has so far not been

granted in any (developed) country. Moreover, the focus of proposed or already

implemented blockchain-related legislation in various countries is on

cryptocurrency trading and on utility tokens – which has largely no effect on the

regulation of security token trading venues. Nevertheless, advisory practices and

press releases by numerous enterprises in the industry give cause for confidence

that trading venues for security tokens will be established shortly. After

all, for ICO teams the tradability of a token is an important criterion affecting its

design.

Final Remarks

The consummate ease with which tokens can be issued, transferred, and equipped

with automated payment functions could be the basis for an “internet of

finance” – a new generation of financial markets in which even the smallest

projects can quickly and safely obtain external funding without intermediaries.

Imagine for example a small bakery in a village which can get funding for a new

oven from its loyal customers by issuing a tokenized micro-bond with automated

interest payment features, or a movie project which automatically pays out a share

of its revenue to the community of fans that funded it with every download. The

indirect interaction between capital seekers and capital suppliers makes not only

large, global funding rounds possible but also promotes stronger relationships

between small investors and their local economy.

Moreover, a blockchain-based, decentralized trading system provides greater

stability and safety, as the absence of intermediaries removes potential points of

failure and middlemen whose incentives are not necessarily aligned with those of

investors. In order for this technology to achieve its full potential for creating an

59 See “SIX to launch full end-to-end and fully integrated digital asset trading, settlements and custody training” [press release], SIX Group AG, July 6, 2018.

“2016 has proven to be the year

where the most forward-thinking

financial institutions are actually

using blockchain technologies for

payments and settlement rather

than as an experiment”

Chris Larsen

Page 65: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

65

Twitter: @CryptoManagers

attractive capital market for companies and investors, existing regulations have to

be applied with sound judgment and a sense of proportion. Luckily the legislative

pendulum is currently swinging toward deregulation again, and more and more

regulatory exemptions are planned, particularly for start-up companies and small

and medium-sized enterprises.60 However, in order to make it possible for

unicorns and already successful companies to obtain adequate funding in their

home markets, more than exemptions for small projects will be needed. In a

global financial market characterized by mobile talent, courage on the

part of regulators to open up and liberalize markets stands to be

rewarded.

60 See “Fact Sheet Frequently asked questions: Easier access to financing for smaller businesses through capital

markets” [press release], European Commission, May 24, 2018.

Page 66: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

Cryptocurrencies.

The New Asset Class.

Regulated | Diversified | Liquid

Information about the fund strategy for professional investors (according to MiFID) only.

www.cryptofunds.li

Page 67: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

**

About Us

The Team

The Report

As a sister report to the internationally acclaimed In Gold We Trust report, the Crypto Research Report brings the

same quality and rigor to understanding the cryptocurrency market. The Crypto Research Report is a report

produced by Incrementum AG.

The Company

Incrementum AG is an owner-managed and fully licensed asset manager & wealth manager based

in the Principality of Liechtenstein.

What makes us stand out in the asset management space? We evaluate all our investments not only from a

global economic perspective but also by taking into account global monetary dynamics. This analysis produces what

we consider a truly holistic view of the state of financial markets. We believe our profound understanding of

monetary history, out-of-the-box reasoning and prudent research allows our clients to prosper in this challenging

market environment.

Page 68: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

**

In order to provide accurate information on the most important and recent updates in the crypto

space, a diverse team of thought-leaders, academics, and finance experts form our board of

advisors. The mission of our board is to stimulate discussion on the most pressing risks and opportunities in the

cryptocurrency market. Our advisors come from different countries, different education paths, and different

careers. However, they all have one trait in common: their avid interest in the blockchain technology and

cryptocurrencies. To stay up-to-date, the advisory board meets on a regular basis to discuss current affairs and the

next quarter’s outlook. All meeting minutes are posted as a transcript and released for free on our website at

www.CryptoResearch.Report. Our board members include:

Max Tertinegg

Max Tertinegg is the CEO and co-founder of Coinfinity in Graz. Since

2014, Mr. Tertinegg has worked with merchants, investors, and regulators in

Austria to build a cryptocurrency community. Currently, he is working on

cryptocurrency storage solutions that are affordable and easy to use.

Oliver Völkel

Based in Vienna, Oliver Völkel is a partner at StadlerVölkel Attorneys

at Law. He assists corporations and banks in all stages of capital market issuings

and private placements (national and international). His focus is on new means of

financing vehicles (initial coin offerings, initial token offerings) and drafting and

negotiation of cross-border facility agreements and security-documentation, also

in connection with cryptocurrencies and tokens. Mr. Völkel also advises on other

cryptocurrency related banking matters, regulatory matters, capital markets

regulation, general corporate, and corporate criminal matters.

Joseph Annuzzi Jr.

Joseph Annuzzi Jr is the founder and CEO of a stealth cryptocurrency

decentralized exchange and the sole inventor of a cryptocurrency

secret key protection algorithm designed for consumers. He is a

software architect and entrepreneur from Silicon Valley and an author of a series

of computer science text books published by Pearson Education, Inc. He also

works with crypto custody solutions.

Advisors

Page 69: January 2019 Edition V. - cryptoresearch.report · deteriorate, thrusting bitcoin into a death spiral. That is, without the mining activities supporting the ledger that maintains

**

We sincerely want to thank the following friends for their outstanding support:

Our knowledgeable advisors including Max Tertinegg, Oliver Völkel, and Joseph Annuzzi Jr., the generous

authors who contributed to this report including Nikolaus Jilch, Christian Meisser, and Patrick Valovic. We are

also grateful to our wonderful research analysts Friedrich Zapke and Cristian Ababii.

Contact:

Incrementum AG

Im alten Riet 102

9494 – Schaan/Liechtenstein

www.incrementum.li

http://www.cryptoresearch.report

Email: [email protected]

Disclaimer:

This publication is for information purposes only, and represents neither investment advice, nor an investment

analysis or an invitation to buy or sell financial instruments. Specifically, the document does not serve as a

substitute for individual investment or other advice. The statements contained in this publication are based on the

knowledge as of the time of preparation and are subject to change at any time without further notice. The authors

have exercised the greatest possible care in the selection of the information sources employed, however, they do

not accept any responsibility (and neither does Incrementum AG) for the correctness, completeness or timeliness

of the information, respectively the information sources, made available, as well as any liabilities or damages,

irrespective of their nature, that may result there from (including consequential or indirect damages, loss of

prospective profits or the accuracy of prepared forecasts.

Copyright: 2019 Incrementum AG. All rights reserved.